People v. Borja
REITERATIONFacts
The Antecedents: Petitioner Engr. Roger F. Borja, in his capacity as General Manager C of the San Pablo Water District, was charged with violations of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) in three Informations filed with the Regional Trial Court (RTC) of San Pablo City, Laguna, Branch 30. Procedural History: Borja filed a Motion to Suspend Arraignment, alleging that a pending civil case, Feliciano v. Commission on Audit (G.R. No. 147402), involving the issue of whether local water districts are private or government-owned or controlled corporations (GOCCs), presented a prejudicial question. He argued that if local water districts were deemed private corporations, the graft cases against him would not prosper as he would not be a public officer covered by Rep. Act No. 3019. The RTC denied his motion and subsequent motion for reconsideration. Borja then filed a petition for certiorari with the Court of Appeals (CA), which dismissed his petition for lack of merit, noting previous rulings that local water districts are GOCCs. The CA also denied his motion for reconsideration. The Petition: Aggrieved, Borja filed a petition for review on certiorari before the Supreme Court, assailing the CA's Decision and Resolution. He argued that the CA erred in dismissing his petition and in not applying established jurisprudence to order the suspension of his arraignment.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari and the motion for reconsideration; and whether the Court of Appeals erred in not applying established jurisprudence in resolving to dismiss the petition for certiorari. Whether there was a prejudicial question warranting the suspension of the proceedings of the graft cases.
Ruling
The petition is bereft of merit. The assailed Decision dated March 19, 2004, and Resolution dated June 28, 2004, of the Court of Appeals in CA-G.R. SP. No. 77453 are hereby AFFIRMED. Costs against the petitioner.
Ratio Decidendi
On the Court of Appeals' ruling: The Court found no error in the Court of Appeals' dismissal of Borja's petition for certiorari. The appellate court correctly noted that the Supreme Court had already consistently ruled that local water districts are GOCCs. Thus, the CA did not err in refusing to suspend the arraignment based on the alleged prejudicial question. The CA's decision was in line with established legal principles and prior rulings of the Supreme Court. The Court also noted that at the time Borja filed his petition before the Supreme Court, more than six months had elapsed since the Court had decided the Feliciano case. This further weakened his claim, as the issue he sought to be resolved had already been definitively settled by the Supreme Court. On the issue of prejudicial question: The Court held that Borja's contention of a prejudicial question was devoid of legal basis. It was settled jurisprudence, even before the Feliciano case, that local water districts are GOCCs and not private corporations. This is because local water districts derive their existence from Presidential Decree No. 198, as amended, and not from the Corporation Code. Therefore, Borja, as an officer of a local water district, is considered a public officer and can be indicted for violations of Rep. Act No. 3019. The pendency of the Feliciano case did not present a novel issue that required resolution before proceeding with the graft cases against Borja.
Main Doctrine
The existence of a pending civil case does not constitute a prejudicial question that warrants the suspension of criminal proceedings for violation of Republic Act No. 3019 if the issue in the civil case has already been settled by jurisprudence, particularly concerning the classification of local water districts as government-owned or controlled corporations (GOCCs).