Eric A. Cabarios v.

People of the Philippines

G.R No. 228097-103 & 228139-41 l September 29, 2021

Justice Amy Lazaro-Javier

Facts:

The plaintiff in this case, Eric A. Cabrios was charged with five counts of violation of
Section 3(e) of Republic Act (RA) 3019, the Anti-Graft Corrupt Practices Act, and five counts of
misappropriation of public funds by falsifying public documents under Article 217. Under the
Revised Penal Code (RPC), in reference to Articles 171 and 48 of the same. The charges stem
from alleged irregularities in the implementation of the poor relief program of Zamboanga
Sibuge province. An audit conducted by the Commission on Audit (COA) found that many of the
alleged beneficiaries were fictitious or nonexistent, and that the appellant had personally signed
distribution documents to the contrary that he paid the beneficiaries when in fact he cannot see
them.

Issue:

Whether petitioner Eric A. Cabarios is guilty of violation of Section of RA 3019 and

malversation of public funds through falsification of public documents.

Ruling:
YES. The Sandiganbayan acquitted petitioner of the charge and convicted him of five counts
of violation of Section 3(e) of RA 3019 and five counts of misappropriation of public funds
through public documents which he did falsely. The court denied his motion for reconsideration.

The Sandiganbayan made its decision based on the evidence presented during the trial,
noting that the petitioner signed documents proving that he personally paid the beneficiaries,
although even though many of them were fake or non-existent. The court also considered the
evidence of witnesses who emphasized that the beneficiaries could not be identified and that they
had not received any financial support from the plaintiff. The court concluded that the petitioner
had used his position to inflict undue injury intentionally and lawfully on the government
through manifest malice. The court also noted that the audit conducted by the COA supported its
findings of lapses in the implementation of the poor assistance scheme. The Sandiganbayan
therefore ruled that petitioner was guilty of violating Section 3 of RA 3019 and misappropriating
public funds by forging public documents.

The courtroom discovered that the evidence provided during the trial, which includes witness
testimony and accounting reviews, become enough to convict the appellant beyond a reasonable
doubt. The court additionally located that the Sandiganbayan had the discretion to determine the
load and credibility of the evidence provided. The court docket consequently denied the
plaintiff's motion for reconsideration.

The Sandiganbayan convicted petitioner of distorting public funds by using false government
documents in violation of Section 3(e) of RA 3019 based on the facts presented in court. The
court denied petitioner’s motion for reconsideration and affirmed the original decision.
 People of the Philippines v. Domingo Arcega Y Siguenza

G.R No. 237489 l August 27, 2020

Chief Justice Diosdado Peralta

Facts:

In an effort to reverse the Court of Appeals' (CA) decision that reclassified the respondent's
conviction for attempted rape to acts of lasciviousness, the People of the Philippines filed a
petition for review on certiorari in this case. The Iriga City Regional Trial Court (RTC) accused
defendant Domingo Arcega of attempting to commit rape. The information states that on April
25, 2010, while waiting for the complainant, AAA, to pass by after taking a bath, the respondent
made a vulgar attempt to rape her by waylaying and assaulting her. Threats or coercion were
used in the endeavor. After having a bath, AAA stated, the respondent abruptly boxed her neck,
covered her mouth, and hit her in the left eye while she was on her way home. The responder
then tried to undress AAA by stepping on top of her, but she was able to kick him in the crotch
and get away. BBB, AAA's aunt, noticed her enter terrified and weeping after hearing her
screams. BBB was notified by AAA about the attempted rape. The respondent refuted the charge
and stated that he and his spouse were somewhere else when the incident happened.

Issue:

Whether the petitioner can assail the CA's decision in this petition for review on certiorari.

Ruling:
NO. In response, the Supreme Court cites and rejects the double jeopardy doctrine. The
Court emphasizes that whether rendered by a trial court or an appellate court, a judgment of
acquittal is final, irrevocable, and immediately enforceable by Court emphasizes that the
principle of ultimate acquittal is a cornerstone of the criminal justice system. The Court further
explains that, although an appellant may appeal a judgment of acquittal under Rule 65, it must be
shown if the regular court acted was ineffective or expressly exercised discretion of excessive
force or ineffectiveness. The petitioner failed to show any misconduct, breach of due process, or
grave abuse of discretion on the part of the CA in this case. As a result, the decision of the CA is
sustained and the petition for certiorari is denied.

The Supreme Court’s decision is based on the concept of double jeopardy, so that no one
will be tried or convicted twice for the same crime The Court means that a person found not
guilty of a crime will be convicted the acquittal is final and irrevocable, except in cases of
wrongful decision resulting in loss of due process.
 Joan V. Alarilla v. The Honorable Sandigangbayan &People

G.R Nos. 236177-210 l February 3, 2021

Justice Rodil Zalameda

Facts:

Joan V. Alarilla filed a petition for certiorari with the People of the Philippines and the
Sandiganbayan (4th Division) in the present case. Petitioner challenges the denial of both his
request for reconsideration and his request for generality (Re: Dismissal and/or Judicial
Determination of Probable Cause). According to the petitioner, the Sandiganbayan more or less
abused its discretion.

The case began with a complaint alleging that petitioner Rolando L. Lorenzo and her late
husband, Eduardo AA, were not liable for the alleged misconduct. The lawsuit alleged serious
misconduct, dishonesty, and abuse by falsifying government records. Appellant and his spouse
were charged in the complaint with embezzlement of public funds by writing checks for goods
and services that never materialized or were not delivered.

The petitioner filed a motion for reconsideration, arguing that the Ombudsman erred in
finding probable cause against her. The Ombudsman denied the motion, prompting the petitioner
to file a petition for certiorari before Sandiganbayan. The Sandiganbayan denied the petition,
prompting the petitioner to file a motion for reconsideration. The Sandiganbayan also denied the
motion for reconsideration, leading the petitioner to file the present petition for certiorari before
the Supreme Court.

Issue:

Whether the petitioner's right to speedy disposition of cases was violated due to the inordinate
delay in the conduct of the preliminary investigation.
Ruling:
YES. The court granted the petition in favor of the plaintiff. The criminal proceedings
against petitioner should have been discontinued, and the judgments of the Sandiganbayan
declared null and void It was held that the Ombudsman delayed for nine years in the preliminary
investigation and for insufficient cause viewed it as violating their right to speedy redress.

The court held that the right to speedy redress should be uplifted in due course. The
Ombudsman's own procedural rules prohibit the filing of claims for dismissal unless by reason of
lack of jurisdiction, it interferes with the procedures for asserting the right to expeditious
disposal of the claims at the first inquiry of the limits therefore it was sufficient for the
petitioners to assert their rights in due course at the first opportunity. The court found that the
plaintiff consistently asserted his rights, did not stop, and did not sleep. The court concluded that
the Sandiganbayan gravely abused its discretion by refusing to sustain petitioner's right to
expedite proceedings.
MEMBERS:

Cabanero, Michaela Marie

Duenas, Reca Mae

Sosas, Carla

Pateno, Cyren Mae

Villavelez, Cyril Mae