### Facts:
Felipe K. Constantino, the mayor of Malungon, Sarangani Province, along with co-accused Norberto N. Lindong, was charged with violating Section 3(e) of Republic Act No. 3019 (The Anti-Graft and Corrupt Practices Act) for allegedly entering into an overpriced lease agreement for heavy equipment with Norlovanian Corporation. Despite resolutions authorizing the mayor to purchase equipment on a five-year amortization basis, Constantino executed a lease agreement with a significantly higher total cost. Both parties proceeded to trial, pleading not guilty.
The prosecution argued the lease/purchase contract was detrimental to the municipal government, presenting evidence of failed public biddings and a subsequent unauthorized lease agreement. The defense, on the other hand, maintained the transaction was a lease/purchase agreement within the scope of a Sangguniang Bayan resolution and even provided documentation implying concurrence from municipal officials.
The Sandiganbayan found both Constantino and Lindong guilty, resulting in separate appeals to the Supreme Court: Constantino seeking a review on the decision and Lindong challenging orders related to the execution of judgment against him.
### Issues:
1. Whether Felipe K. Constantino violated Section 3(e) of R.A. No. 3019 by entering into the disputed lease agreement.
2. Whether Constantino acted with manifest partiality, evident bad faith, or gross inexcusable negligence.
3. Whether Norberto N. Lindong, as co-conspirator, can be held liable despite the alleged offense committed through negligence.
4. The applicability of the decision in Constantino v. Hon. Ombudsman Desierto in the present case.
5. Whether the death of Constantino affects the merits of the case and its implications on Lindong’s liability.
### Court’s Decision:
The Supreme Court, after a comprehensive review, determined that:
1. Constantino did not violate Section 3(e) of R.A. No. 3019 as the prosecution failed to demonstrate guilt beyond reasonable doubt. It was found that the lease/purchase agreement was within the authorization given by the Sangguniang Bayan resolutions.
2. There was no evidence of manifest partiality, evident bad faith, or gross inexcusable negligence on the part of Constantino.
3. Since Constantino was not found to have committed the offense, consequently, Lindong, as a co-conspirator in a case based on negligent action, cannot be held liable.
4. The Court reiterated the findings in Constantino v. Hon. Ombudsman Desierto, highlighting that administrative findings are crucial and have a bearing on criminal liability.
5. The demise of Constantino rendered his petition moot but prompted the Court to review and ultimately led to Lindong’s absolution in the interest of justice.
### Doctrine:
This case reaffirms the principles regarding the violation of Section 3(e) of R.A. No. 3019, emphasizing the necessity for the prosecution to clearly establish elements such as evident bad faith, manifest partiality, or gross inexcusable negligence. It also underlines the interconnectedness of administrative findings with criminal liability and the significant impact of prior resolved cases on similar subsequent cases.
### Class Notes:
– Elements of Section 3(e) of R.A. No. 3019 include (1) being a public officer, (2) causing undue injury or giving unwarranted benefits, (3) in the performance of official duties, (4) through manifest partiality, evident bad faith, or gross inexcusable negligence.
– The principle of conclusiveness of judgment and its implications in connected cases.
– How administrative findings can have bearing on criminal liability, especially under the Anti-Graft Law.
### Historical Background:
This case reflects the intricate process of accountability and legal scrutiny involved in allegations of corruption within public offices in the Philippines. It underscores the judiciary’s role in dissecting administrative actions against the backdrop of anti-corruption laws, highlighting the importance of evidential sufficiency and procedural adherence to ensure justice and integrity in public service.
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