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Title
Guy v. People

Case Ponente Decision Date

G.R. Nos. 166794-96, 166880-82 & TINGA, J : 2009-03-20
167088-90

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Facts
This case involves consolidated petitions for review assailing the decision of the Sandiganbayan in Criminal
Cases No. 26508-10. The petitioners in this case are officers and employees of the City Engineer's Office of
the City of Tacloban, as well as the Barangay Chairman and Barangay Treasurer of Barangay 36, Sabang
District, Tacloban City. They were charged with violation of Section 3 (e) of Republic Act No. 3019 (R.A. No.
3019), also known as the Anti-Graft and Corrupt Practices Act. The charges were in connection with the
construction of three infrastructure projects in Barangay 36. The Commission on Audit conducted an audit
investigation and found irregularities in the construction projects, including the awarding of contracts
without proper plans and specifications, failure to abide by the plans, and the absence of material
documents. The Sandiganbayan found material defects in the projects and that the contract costs were
overpriced.

Issue
The main issue in this case is whether the accused committed the offense charged in relation to their public
office. The accused argued that the Informations failed to sufficiently show the close intimacy between
their discharge of official duties and the commission of the offense charged.

Ruling
The court ruled that the Informations sufficiently showed the close intimacy between the accused's
discharge of official duties and the commission of the offense charged. The court explained that it is not
enough to merely allege in the information that the crime was committed in relation to the accused's office;
there must be specific factual allegations that indicate the close intimacy between the discharge of the
accused's official duties and the commission of the offense. In this case, the Informations alleged that the
accused, in their capacity as public officials, caused the construction of the subject structures without
following the approved program of work and drawing plan, and gave unwarranted benefits to themselves
and to Amago Construction. These allegations were deemed sufficient to establish the close connection
between the accused's official duties and the commission of the offense.

Ratio
The court's decision was based on the requirement that the Informations must contain specific factual
allegations that show the close intimacy between the accused's discharge of official duties and the
commission of the offense. In this case, the Informations alleged that the accused, in their capacity as
public officials, caused the construction of the subject structures without following the approved program
of work and drawing plan, and gave unwarranted benefits to themselves and to Amago Construction. These
:
 allegations were deemed sufficient to establish the close connection between the accused's official duties
and the commission of the offense. Therefore, the court ruled that the Informations were sufficient.

Summary
The Supreme Court denied the petitions and affirmed the decision of the Sandiganbayan. The court ruled
that the Sandiganbayan had jurisdiction over the case and that the allegations in the informations were
sufficient. The court also found that the prosecution had proven the elements of the offense and the
existence of conspiracy. The accused were found guilty of violating Section 3 (e) of Republic Act No. 3019
and were sentenced to imprisonment, perpetual disqualification from public office, and to indemnify the
government. The court's decision was based on the requirement that the Informations must contain specific
factual allegations that show the close intimacy between the accused's discharge of official duties and the
commission of the offense. In this case, the Informations alleged that the accused, in their capacity as
public officials, caused the construction of the subject structures without following the approved program
of work and drawing plan, and gave unwarranted benefits to themselves and to Amago Construction. These
allegations were deemed sufficient to establish the close connection between the accused's official duties
and the commission of the offense.

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