016 PEOPLE v.

SANDIGANBAYAN (Yap) import of the ruling therein is that proof of undue injury must be established
9 September 2015 | Jardeleza, J. | Specific amount of damage; ultimate facts by the prosecution during the trial and not when the Information is filed.
Nowhere in Llorente did we require that undue injury be specified,
PETITIONER: People of the Philippines quantified and proved to the point of moral certainty at the time of the filing
RESPONDENTS: Sandiganbayan (Fourth Division), Jessie Castillo, of the Information. Third, outright Quashal of the information is not the
Melencio Arciaga and Emerenciano Arciaga proper cause of action. §4 of Rule 117 of the Rules of Court provides that
“if it is based on the ground that the facts charged do not constitute an
SUMMARY: Jessie B. Castillo was then the mayor of Bacoor, Cavite when offense, the prosecution shall be given by the court an opportunity to correct
he was charged before the Sandiganbayan with a violation of §3(e) of RA the defect by amendment.”
3019 for allegedly giving unwarranted benefits to Melencio and
Emerenciano Arciaga by allowing them to operate the Villa Esperanza DOCTRINE: For as long as the ultimate facts constituting the offense have
Dumpsite without the required Environmental Compliance Certificate been alleged, an Information charging a violation of Section 3 (e) of RA
(ECC) from the Environmental Management Bureau (EMB). An No. 3019 need not state, to the point of specificity, the exact amount of
administrative complaint for simple misconduct was also filed before the unwarranted benefit granted nor specify, quantify or prove, to the point of
Ombudsman, of which the latter found Castillo guilty, but the CA reversed moral certainty, the undue injury caused.
and dismissed this admin complaint on the ground that no misconduct had
been committed as the result was still achieved (ie., amount of garbage in FACTS:
the area reduced anyway, even if it took a longer period of time). In the RA
3019 case before the Sandiganbayan, Castillo filed a motion to dismiss on 1. Jessie B. Castillo was the mayor of Bacoor, Cavite.
the ground that the crime had been decriminalized by RA 9003 and invoked 2. An information was filed before the Sandiganbayan against Castillo
the CA’s dismissal of the admin complaint. He then filed a supplemental charging him of a violation of §3(e) of RA 3019, alleging that he “gave
motion to quash arguing that the information failed to allege, specify, unwarranted benefits to Melencio and Emerenciano Arciaga by
quantify, and prove the damage done to a point of moral certainty as held in allowing them to operate the Villa Esperanza Dumpsite without the
Llorente v. Sandiganbayan. The special division of the Sandiganbayan required Environmental Compliance Certificate (ECC) from the
granted the motion. Hence, this petition. Environmental Management Bureau (EMB).
3. An administrative complaint for simple misconduct was also filed
The sole issue is whether the amount of damage must be specified, against him for alleged illegal operation of the dumpsite.
quantified, and proven in the information in a charge for giving unwarranted a. The Ombudsman found Castillo guilty of simple misconduct
benefits. (admin).
b. The CA set aside this decision and ordered the complaint’s
The Court ruled in the negative. First, the main purpose of an Information dismissal on the ground that although the solution turned out
is to ensure that an accused is formally informed of the facts and the acts to be a “long-term one, but the end results were just the same
constituting the offense charged. The important purpose of this rule is (1) it ie., the trash has been remarkably reduced…”
enables the accused to suitably prepare his defense; and (2) it allows the 4. Castillo filed with the Sandiganbayan a motion to dismiss on the
accused, if found guilty, to plead his conviction in a subsequent prosecution ground that the case against him had been decriminalized by §37 of
for the same offense (Doctrine). As alleged in the Information, the RA 9003 and he invoked the CA’s dismissal of the administrative
unwarranted benefit was the privilege granted by Castillo to the Arciagas to charge.
operate the dumpsite without the need to comply with the applicable laws, a. In a supplementatl motion to quash, he adds that the
rules, and regulations; the undue injury being residents and students were information does not charge an offense, claiming that the
made to endure the ill-effects of the illegal operation. Second, reliance of claim of injury was not “specified, quantified, and proven to
the defense in Llorente v. Sandiganbayan is misplaced. The validity and the point of moral certainty” as held in the case of Llorente v.
sufficiency of the Information, however, was not an issue in Llorente. The Sandiganbayan.
 b. The special division of the Sandiganbayan granted the motion b. The true test in ascertaining the validity and sufficiency of an
on the ground that undue injury cannot be presumed even after Information is "whether the crime is described in intelligible
a wrong or a violation has been established. Its existence must terms with such particularity as to apprise the accused, with
be proven as one of the elements of the crime. reasonable certainty, of the offense charged."
5. Hence, this appeal. 4. Elements of violation of §3(e) RA 3019 (ie., charge against Castillo):
a. The accused must be a public officer discharging
ISSUE/s: administrative, judicial or official functions;
b. He must have acted with manifest partiality, evident bad
1. Whether an information alleging the grant of unwarranted benefits and faith or gross inexcusable negligence; and
existence of undue injury must state the precise amount of the alleged c. That his action caused any undue injury to any party,
benefit as well as identify, specify, and prove the alleged injury to the including the government, or giving any private party
point of moral certainty. NO — because the purpose of an information unwarranted benefits, advantage or preference in the
is to inform the accused of the charge against him; reliance in Llorente discharge of his functions.
is misplaced because that case dealt with proving damages, not the 5. The Information specifically alleged that Castillo is the Mayor of
sufficiency of the information. Bacoor, Cavite who, in such official capacity, with evident bad faith
and manifest partiality, and conspiring with the Arciagas, wilfully,
RULING: WHEREFORE, petition GRANTED. unlawfully and criminally gave unwarranted benefits to the latter, by
allowing the illegal operation of the Villa Esperanza dumpsite, to the
RATIO: undue injury of the residents and students in the area who had to
endure the ill-effects of the dumpsite's operation.
1. The main purpose of an Information is to ensure that an accused is 6. For as long as the ultimate facts constituting the offense have been
formally informed of the facts and the acts constituting the offense alleged, an Information charging a violation of Section 3 (e) of RA
charged. No. 3019 need not state, to the point of specificity, the exact amount
2. Where insufficient, an accused in a criminal case can file a motion to of unwarranted benefit granted nor specify, quantify or prove, to the
have the Information against him quashed and/or dismissed before he point of moral certainty, the undue injury caused.
enters his plea. a. As alleged in the Information, the unwarranted benefit was the
a. A motion to quash an Information on the ground that the facts privilege granted by Castillo to the Arciagas to operate the
charged do not constitute an offense should be resolved on the dumpsite without the need to comply with the applicable laws,
basis of the allegations in the Information whose truth and rules, and regulations; the undue injury being residents and
veracity are hypothetically admitted. students were made to endure the ill-effects of the illegal
b. In proceeding to resolve this issue, courts must look into three operation.
matters: (1) what must be alleged in a valid Information; (2) b. The specific extent of the damage are matters of evidence best
what the elements of the crime charged are; and (3) whether raised during the trial; they need not be stated in the
these elements are sufficiently stated in the Information. information.
3. The Rules of Court provide that the cause of the accusation must be 7. Moreover, the rationale for the ultimate facts requirement becomes
stated in terms sufficient to enable a person of common understanding clearer when one considers the period when a motion to quash is filed,
to know what offense is being charged as well as its qualifying and that is, before the accused's arraignment and the parties' presentation
aggravating circumstances and for the court to pronounce judgment. of their evidence. It would be illogical, if not procedurally infirm, to
a. The important purpose of this rule is (1) it enables the accused require specific peso amount allegations of the unwarranted benefit
to suitably prepare his defense; and (2) it allows the accused, and proof of undue injury — to the point of moral certainty, no less —
if found guilty, to plead his conviction in a subsequent at this stage of the criminal proceedings.
prosecution for the same offense 8. Reliance of the defense in Llorente v. Sandiganbayan is misplaced.
 The validity and sufficiency of the Information, however, was not an
issue in Llorente. The import of the ruling therein is that proof of
undue injury must be established by the prosecution during the trial
and not when the Information is filed. Nowhere in Llorente did we
require that undue injury be specified, quantified and proved to the
point of moral certainty at the time of the filing of the Information.
9. Lastly, outright Quashal of the information is not the proper cause of
action. §4 of Rule 117 of the Rules of Court provides that “if it is based
on the ground that the facts charged do not constitute an offense, the
prosecution shall be given by the court an opportunity to correct the
defect by amendment.”
a. This rule allows a case to proceed without undue delay. By
allowing the defect to be cured by simple amendment,
unnecessary appeals based on technical grounds, which only
result to prolonging the proceedings, are avoided.
b. More than this practical consideration, however, is the due
process underpinnings of this rule. As explained by this Court
in People v. Andrade, the State, just like any other litigant, is
entitled to its day in court.