Reyes vs. People

A public officer who renders a quasi‑judicial decision with manifest partiality and evident bad faith, in willful disregard of a final and executory court judgment, thereby causing undue injury to a party or giving unwarranted benefits, advantage, or preference to another, is guilty of violating Section 3(e) of Republic Act No. 3019; however, the act of a DARAB Adjudicator in deciding a case within his jurisdiction—even if done in defiance of a final judicial decision—does not constitute the crime of usurpation of judicial functions under Article 241 of the Revised Penal Code because the Adjudicator is exercising a quasi‑judicial power, not assuming powers that the law vests exclusively in a judge.

Belen Lopez Vda. de Guia owned two parcels of agricultural land in Bulacan covered by TCT No. 209298. In 1975, her son Carlos forged a deed of sale making it appear that Belen had sold the land to him, leading to the issuance of TCT No. 210108 in Carlos’ name. Carlos immediately sold the land to Ricardo San Juan, who obtained TCT No. 210338 and later mortgaged the property. Belen discovered the fraud, filed an adverse claim on the title, and commenced a civil action for cancellation of sale, reconveyance, and damages. After a protracted journey through the courts, the Intermediate Appellate Court (IAC) rendered a decision in 1986 in AC‑G.R. CV No. 02883 that declared the deeds void, ordered reconveyance, and reinstated Belen’s title. That decision became final and executory. Meanwhile, during the pendency of the civil case, the tenants who had been cultivating the land exercised a statutory right of redemption and obtained titles from Ricardo. The subsequent effort by Belen to enforce the final IAC judgment and eject the tenants eventually reached the DARAB, where petitioner Jose Reyes issued the decision challenged in this criminal case.

• The Forged Sale and Subsequent Transfers: Belen Lopez Vda. de Guia (Belen) was the registered absolute owner of two parcels of agricultural land (197,594 sq. m.) in Santa Barbara, Baliwag, Bulacan under TCT No. 209298. On March 19, 1975, her son Carlos de Guia forged a deed of sale purporting that Belen had sold the land to him; TCT No. 209298 was cancelled and TCT No. 210108 was issued in Carlos’ name. The following day, Carlos sold the land to Ricardo San Juan; TCT No. 210108 was cancelled and TCT No. 210338 issued in Ricardo’s name. Ricardo later mortgaged the land to Simeon Yangco.

• Civil Action and the Final IAC Decision: Upon discovering the transfers, Belen filed an adverse claim annotated on TCT No. 210338 and initiated a civil suit for cancellation of sale, reconveyance, and damages against Carlos, Ricardo, and Simeon (Civil Case No. 655‑B). The Court of First Instance initially dismissed the complaint and affirmed the deeds. Belen appealed to the Intermediate Appellate Court (IAC). After an earlier dismissal due to non‑payment of docket fees was set aside, the IAC reinstated the appeal (AC‑G.R. CV No. 02883) and, on February 20, 1986, reversed the trial court. The IAC declared the deed of sale between Belen and Carlos null and void, found Ricardo a purchaser in bad faith, ordered Ricardo to reconvey the land to Belen, and directed the Register of Deeds to cancel the TCTs of Carlos and Ricardo and reinstate Belen’s TCT No. 209298. This decision became final on March 15, 1986; entry of judgment was made on November 7, 1986, and the records were remanded to the RTC of Baliwag, Bulacan.

• Tenants’ Redemption and Titles: During the pendency of the civil case, the tenants (Paulino Sacdalan, Leonardo Sacdalan, Santiago Sacdalan, Numeriano Bautista, and Romeo Garcia) invoked their right of redemption under Section 12 of RA 3844. Ricardo executed a deed of reconveyance in their favor on October 24, 1983. Upon registration, TCT No. 210338 was cancelled and TCT No. 301375 issued in the tenants’ names, later subdivided into individual titles.

• Enforcement of the Final Judgment and Contempt Proceedings: Belen moved for execution of the IAC decision in the RTC. When the writ was about to be implemented, she learned of Ricardo’s reconveyance to the tenants. She sought to hold Ricardo and the tenants in contempt for circumventing the final judgment. On October 12, 1987, the RTC found them in contempt, fined them, and ordered them to reconvey the land and deliver the harvest to Belen. The Court of Appeals (CA) in CA‑G.R. SP No. 14783 affirmed the reconveyance order but set aside the contempt citation. That CA decision became final and executory on July 31, 1989.

• DARAB Proceedings and Petitioner’s Decision: On November 8, 1988, Belen, through her attorney‑in‑fact Melba G. Valenzuela, filed a complaint for ejectment and collection of rents against the tenants before the DARAB (DARAB Case No. 034‑BUL’88). Petitioner Jose Reyes, as Provincial Adjudicator of DARAB in Bulacan, rendered a decision on March 16, 1993, dismissing Belen’s complaint and affirming the tenants’ individual TCTs. He ordered Belen and all persons acting in her behalf to permanently cease and desist from ousting the tenants. He later granted the tenants’ motion for execution on March 31, 1993. The DARAB Central Office affirmed, but the CA reversed and ordered the tenants to vacate, deliver possession, and pay rents; this CA ruling was ultimately affirmed by the Supreme Court in G.R. No. 128967.

• Criminal Charges and Evidence at Trial: The Ombudsman charged petitioner with violation of Section 3(e) of RA 3019 and usurpation of judicial functions. The prosecution adduced evidence—including Belen’s position paper, the entry of judgment in AC‑G.R. CV No. 02883, Belen’s TCT reflecting the entry of judgment, and an addendum to her position paper—all of which petitioner conceded he had read and examined before rendering his DARAB decision. Petitioner thus had actual knowledge that the CA decision had long become final and executory and had declared Belen the true owner of the land.

• No Evident Bad Faith, Manifest Partiality, or Gross Inexcusable Negligence: Petitioner maintained that his decision in DARAB Case No. 034‑BUL’88 was rendered solely on the basis of his perception of the letter and spirit of pertinent laws and upon a thorough appreciation of the facts and the law; he argued that there was no showing of evident bad faith, manifest partiality, or gross inexcusable negligence on his part.

• Usurpation of Judicial Functions Not Committed: Petitioner insisted that his rendition of a decision within his authority as Provincial Adjudicator did not amount to the felony of usurpation of judicial functions under Article 241 of the Revised Penal Code.

• Graft Conviction Proper: The People, through the Office of the Ombudsman, contended that petitioner acted with manifest partiality and evident bad faith by rendering a decision that willfully ignored and contradicted the final and executory CA decision in AC‑G.R. CV No. 02883, causing undue injury to Belen and giving unwarranted benefit to the tenants.

• Usurpation by Obstructing Execution of a Judicial Decision: The prosecution argued that petitioner, by issuing a ruling that effectively obstructed the execution of a final court order, assumed judicial powers and committed usurpation of judicial functions.

• Violation of Section 3(e) of RA 3019: Whether petitioner was guilty of violating Section 3(e) of RA 3019 in rendering his decision in DARAB Case No. 034‑BUL’88.

• Usurpation of Judicial Functions: Whether petitioner was guilty of usurpation of judicial functions as defined and penalized under Article 241 of the Revised Penal Code.

• Violation of Section 3(e) of RA 3019: The conviction was affirmed. All three elements of the offense were established. Petitioner was a public officer discharging judicial or quasi‑judicial functions as a DARAB Provincial Adjudicator. He acted with both manifest partiality and evident bad faith: he rendered a decision that completely contradicted and disregarded the immutable final judgment in AC‑G.R. CV No. 02883, despite having read and examined the documents proving its finality. This was a total and willful disregard of a binding court decision, compounded by his immediate grant of the tenants’ motion for execution, which laid bare his inclination to favor the tenants. The bad faith was further evident in his arrogant refusal to obey the CA ruling that bound him and all parties. The CA and the Supreme Court had earlier characterized his conduct as “an utter disrespect to the judiciary,” vested with a “dishonest purpose,” and a “contumacious attitude.” His act caused undue injury to Belen, who was forced to incur substantial litigation expenses (around ₱990,000.00) and suffered prolonged deprivation of ownership, possession, and fruits of the land, while simultaneously giving unwarranted benefit and advantage to the tenants by allowing them to remain in possession and enjoy the produce. Proof of the precise quantum of damage was not essential; it was sufficient that the injury and benefit were substantial and not negligible.

• Usurpation of Judicial Functions: The conviction was reversed and set aside. Usurpation of judicial functions under Article 241 of the Revised Penal Code requires that the offender, who is not a judge, performs an act the authority for which the law vests exclusively in a judge. Petitioner’s task of adjudicating the claims of opposing parties in the DARAB was a quasi‑judicial function closely akin to that of a judge. He did not assume judicial powers beyond his legal authority, nor did he perform an act that only a judge could perform. The acts constitutive of usurpation of judicial functions were therefore lacking.

• Mitigating Circumstance of Old Age: The Sandiganbayan erroneously appreciated the mitigating circumstance of old age. Article 13(2) of the Revised Penal Code applies only when the offender was over 70 years of age at the time of the commission of the offense. Petitioner was only 63 years old when he committed the acts charged and thus was not entitled to the mitigating circumstance.

• Elements of Section 3(e) of RA 3019 — The offense requires: (1) the accused is a public officer discharging administrative, judicial, or official functions; (2) the accused acted with manifest partiality, evident bad faith, or gross inexcusable negligence; and (3) the action caused undue injury to any party, including the Government, or gave any private party unwarranted benefits, advantage, or preference. Proof of any one of the modes in the second element is sufficient for conviction. For the third element, proof of the extent or quantum of damage is not essential; it is enough that the injury or benefit is perceived to be substantial and not merely negligible.

• Manifest Partiality — Exists when the accused has a clear, notorious, or plain inclination or predilection to favor one side or person rather than another; it is synonymous with bias, which excites a disposition to see and report matters as they are wished for rather than as they are.

• Evident Bad Faith — Connotes a manifest deliberate intent on the part of the accused to do wrong or to cause damage; it contemplates a breach of sworn duty through some perverse motive or ill will.

• Immutability of Final Judgments — A decision that has become final and executory is immutable and can no longer be modified in any respect, whether the modification would be to correct erroneous conclusions of fact or law, and whether made by the court that rendered it or by the highest court. The reason is that litigation must end, and the effective administration of justice requires that the winning party not be deprived of the fruits of the verdict.

• Quasi‑Judicial Officer Not Liable for Usurpation Under Article 241 — An officer of the executive branch who decides a case within the scope of his statutory quasi‑judicial authority does not thereby assume judicial powers or obstruct the execution of a judge’s order within the meaning of Article 241 of the Revised Penal Code. The offense of usurpation of judicial functions contemplates acts that the law vests exclusively in a judge; adjudication by a DARAB Adjudicator, even if erroneous or defiant of a final court decision, is not such an act.

• Mitigating Circumstance of Old Age — The privilege under Article 13(2) of the Revised Penal Code applies only when the offender was over 70 years old at the time of the commission of the offense, not at the time of trial or sentencing.

• “The decision rendered on February 20, 1986 in AC‑G.R. CV No. 02883 … became final on March 15, 1986. … Due to its finality, the decision in AC‑G.R. CV No. 02883 became immutable, and could no longer be modified in any respect, whether the modification was to correct erroneous conclusions of fact or law, whether made by the court that rendered it or by the highest court of the land. The reason for such immutability is that a litigation must end sometime, and an effective and efficient administration of justice requires that the winning party be not deprived of the fruits of the verdict once a judgment becomes final.”

• “Yet, the petitioner still rendered his decision in DARAB Case No. 034 BUL’88 that completely contradicted and disregarded the decision in AC‑G.R. CV No. 02883 … He thereby exhibited manifest partiality, for such decision of his was a total and willful disregard of the final decision in AC‑G.R. CV No. 02883. His granting the tenants’ motion for execution made his partiality towards the tenants and bias against Belen that much more apparent.”

• “Similarly, the petitioner’s evident bad faith displayed itself by his arrogant refusal to recognize and obey the decision in AC‑G.R. CV No. 02883, despite his unqualified obligation as Provincial Adjudicator to abide by the CA’s ruling that was binding on him as Provincial Adjudicator and on all the parties in DARAB Case No. 034‑BUL’88.”

• “In usurpation of judicial function, the accused, who is not a judge, attempts to perform an act the authority for which the law has vested only in a judge. However, the petitioner’s task as Provincial Adjudicator when he rendered judgment in DARAB Case No. 034 BUL’88 was to adjudicate the claims of the opposing parties. As such, he performed a quasi‑judicial function, closely akin to the function of a judge of a court of law. He could not be held liable under Article 241 of the Revised Penal Code, therefore, considering that the acts constitutive of usurpation of judicial function were lacking herein.”

• Albert v. Sandiganbayan, G.R. No. 164015, February 26, 2009, 580 SCRA 279 — Cited for the enumeration of the essential elements of Section 3(e) of RA 3019 and for the definition of manifest partiality.

• Velasco v. Sandiganbayan, G.R. No. 160991, February 28, 2005, 452 SCRA 593 — Also cited for the elements of Section 3(e) of RA 3019.

• Fonacier v. Sandiganbayan, G.R. No. 50691, December 5, 1994, 238 SCRA 655 — Relied upon for the rule that proof of any one of the modes (manifest partiality, evident bad faith, or gross inexcusable negligence) suffices for conviction, and for the definition of gross inexcusable negligence and the proposition that proof of quantum of damage is not essential.

• Reyes v. Atienza, G.R. No. 152243, September 23, 2005, 470 SCRA 670 — Cited for the definition of evident bad faith as a manifest deliberate intent to do wrong or cause damage.

• Villanueva v. Sandiganbayan, G.R. No. 105607, June 21, 1993, 223 SCRA 543 — Invoked for the definition of evident bad faith as a breach of sworn duty through perverse motive or ill will.

• Philippine Veterans Bank v. Estrella, G.R. No. 138993, June 27, 2003, 405 SCRA 168 — Cited in support of the principle of immutability of final judgments.

• Miñoso v. Pamulag, A.M. No. P‑05‑2067, August 31, 2005, 468 SCRA 407 — Referred to for the definition of usurpation of judicial function: an attempt by a non‑judge to perform an act the authority for which the law vests only in a judge.

• People v. Nacional, G.R. Nos. 111294‑95, September 7, 1995, 248 SCRA 122 — Cited for the rule that the mitigating circumstance of old age under Article 13(2) of the Revised Penal Code applies only when the offender was over 70 at the time of the commission of the offense.

• Section 3(e), Republic Act No. 3019 (Anti‑Graft and Corrupt Practices Act) — Defines the offense of causing undue injury to any party or giving unwarranted benefits through manifest partiality, evident bad faith, or gross inexcusable negligence. Applied to petitioner’s deliberate disregard of a final court decision, which caused injury to Belen and benefited the tenants.

• Article 241, Revised Penal Code — Punishes any officer of the executive branch who shall assume judicial powers or obstruct the execution of any order or decision rendered by a judge within his jurisdiction. Held inapplicable because petitioner performed a quasi‑judicial, not purely judicial, function and did not assume powers exclusively vested in judges.

• Article 13(2), Revised Penal Code — Mitigating circumstance of old age (over 70 years) at the time of the commission of the offense. The Court ruled that petitioner, being 63 years old when he rendered the questioned decision, was not entitled to this privilege.

• Section 9, Republic Act No. 3019 — Prescribes the penalty for violations of Section 3 of RA 3019: imprisonment for not less than six years and one month nor more than fifteen years, and perpetual disqualification from public office. Applied in imposing the indeterminate sentence.

• Section 1, Indeterminate Sentence Law — Provides that if the offense is punished by a special law, the indeterminate penalty must have a maximum that does not exceed the maximum fixed by the law and a minimum not less than the minimum prescribed. The Court upheld the Sandiganbayan’s sentence of six years and one month minimum to ten years maximum.

Associate Justice Conchita Carpio Morales (Chairperson), Associate Justice Arturo D. Brion, Associate Justice Roberto A. Abad (on official leave but listed as concurring per Special Order No. 843), and Associate Justice Martin S. Villarama, Jr.

None.