**Jaravata vs. The Hon. Sandiganbayan and the People of the Philippines**
### Facts:
Hilario Jaravata, the Assistant Principal of Leones Barangay High School in Tubao, La Union, was accused of violating Section 3(b) of the Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act) between April 30, 1979, and May 25, 1979. The accusation centered around Jaravata demanding and receiving payments from his classroom teachers in exchange for facilitating the release of their salary differentials.
The case originated when, on January 5, 1979, Jaravata informed the teachers about the approval of their salary differential release for 1978. An agreement was made wherein Jaravata would expedite the paperwork in Manila, with teachers reimbursing his expenses. However, Jaravata received amounts exceeding the agreed reimbursement from four teachers, totaling an excess of P194.00 over the rightful share.
After trial, the Sandiganbayan found Jaravata guilty, sentencing him to imprisonment and perpetual special disqualification from public office. Jaravata challenged this decision in the Supreme Court, arguing legal issues concerning the application of Section 3(b) of R.A. 3019.
### Issues:
1. Whether or not Jaravata’s actions constituted a violation of Section 3(b) of Republic Act No. 3019, given the circumstances of his intervention in the salary differential payment.
### Court’s Decision:
The Supreme Court reversed the Sandiganbayan’s decision, ruling in favor of Jaravata. The Court reasoned that while Jaravata was a public officer and had received amounts in excess as gifts or benefits, his role did not fall under the scope defined by Section 3(b) of R.A. 3019. Specifically, Jaravata’s actions to facilitate the salary differential payment did not constitute official intervention required by law in the transaction. Thus, he did not violate the said provision.
### Doctrine:
The Supreme Court clarified that Section 3(b) of the Anti-Graft and Corrupt Practices Act applies to public officers whose official duties, as mandated by law, require them to intervene in a transaction or contract. Activities outside this scope, even if undertaken by a public officer to expedite a process not legally part of their duties, do not constitute a violation under this provision.
### Class Notes:
– **Key Elements for Section 3(b) of R.A. 3019**: Public officer, intervention in transactions or contracts as part of official duties, the intervention required by law.
– **Application**: For a violation under Section 3(b), it must be shown that the public officer’s intervention in the transaction was mandated as part of their official duties by law, not just by agreement or for expedience.
### Historical Background:
The case provides insight into judicial interpretation of anti-graft laws in the Philippines, specifically on what constitutes “intervention” by a public officer in government transactions. It distinguishes between actions officially required by law and personal efforts to assist or expedite processes, indicating a narrow application of penal provisions against graft.
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