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    Santillano V People

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    Tommy Doncila
    Engr. Ricardo Santillano appealed his conviction of three counts of violating the Anti-Graft and Corrupt Practices Act. The Court ruled that private persons can be held liable under the Act for inducing public officials to commit prohibited acts. While Santillano claimed only public officials could be liable, the law clearly punishes those who induce offenses as well as those who commit them. The Court found conspiracy between Santillano, Ecleo, and Navarra was established based on their approval and receipt of overpayments without justification, showing a concerted effort to deprive government funds.

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    Santillano V People

    Uploaded by

    Tommy Doncila
    232 views2 pages
    Engr. Ricardo Santillano appealed his conviction of three counts of violating the Anti-Graft and Corrupt Practices Act. The Court ruled that private persons can be held liable under the Act for inducing public officials to commit prohibited acts. While Santillano claimed only public officials could be liable, the law clearly punishes those who induce offenses as well as those who commit them. The Court found conspiracy between Santillano, Ecleo, and Navarra was established based on their approval and receipt of overpayments without justification, showing a concerted effort to deprive government funds.

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    Santillano v People

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    Engr. Ricardo Santillano appealed his conviction of three counts of violating the Anti-Graft and Corrupt Practices Act. The Court ruled that private persons can be held liable under the Act for inducing public officials to commit prohibited acts. While Santillano claimed only public officials could be liable, the law clearly punishes those who induce offenses as well as those who commit them. The Court found conspiracy between Santillano, Ecleo, and Navarra was established based on their approval and receipt of overpayments without justification, showing a concerted effort to deprive government funds.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    232 views2 pages

    Santillano V People

    Uploaded by

    Tommy Doncila
    Engr. Ricardo Santillano appealed his conviction of three counts of violating the Anti-Graft and Corrupt Practices Act. The Court ruled that private persons can be held liable under the Act for inducing public officials to commit prohibited acts. While Santillano claimed only public officials could be liable, the law clearly punishes those who induce offenses as well as those who commit them. The Court found conspiracy between Santillano, Ecleo, and Navarra was established based on their approval and receipt of overpayments without justification, showing a concerted effort to deprive government funds.

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    © All Rights Reserved
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    Santillano v.

    People Doctrine: Any person who induces or causes a


    GR No. 175045-46, March 3, 2010 public official to commit prohibited acts under
    Velasco, Jr., J RA 3019 are also liable for the same
    Doncila | Group 1
    Facts:
    Petitioner: Engr. Ricardo L. Santillano
    Respondent: People of the Philippines  Engr. Ecleo appealed the judgement
    holding him guilty of three counts of
    Topic: Crimes Committed by Public Officers violation of Sec. 3(e) of RA 3019 or the
    Anti-Graft and Corrupt Practices Act in
    Provisions: criminal case nos. 24467, 24468 and
    24469.
    “Section 3. Corrupt practices of public officers.— Issue:
    In addition to acts or omissions of public officers  WON only public officers can be
    already penalized by existing law, the following convicted under RA 3019
    shall constitute corrupt practices of any public Ruling:
    officer and are hereby declared to be unlawful:  No. The Court held that even private
    xxxx persons can be held liable under RA
    (e) Causing any undue injury to any party, 3019. While Santillano asserted that the
    including the Government, or giving any private Sandiganbayan allegedly inserted an
    party any unwarranted benefits, advantage or additional phrase to the law in order to
    preference in the discharge of his official have a legal basis in holding him liable,
    administrative or judicial functions through the Court dismissed this as without
    manifest partiality, evident bad faith or gross merit.
    inexcusable negligence. This provision shall  The law clearly punishes not only public
    apply to officers and employees of offices or officers who committed prohibited acts
    government corporations charged with the grant under sec. 3, but also those who induce
    of licenses or permits or other concessions. x x x” or cause the public official to commit
    those offenses.
    “Section 4. Prohibition on private individuals.—  Sec. 9 includes private persons as liable
    xxxx for violations under Secs. 3, 4, 5, and 6.
    (b) It shall be unlawful for any person knowingly  Go, citing Luciano v. Estrella, Singian, Jr.
    to induce or cause any public official to commit v. Sandiganbayan and Domingo v.
    any of the offenses defined in Section 3 hereof. Sandiganbayan, states that private
    persons found acting in conspiracy with
    Section 9. Penalties for violations.—(a) Any public officers may be held liable for the
    public officer or private person committing any applicable offenses found in Sec. 3 of RA
    of the unlawful acts or omissions enumerated in 3019.
    Sections 3, 4, 5 and 6 of this Act shall be punished  Santillano still asserts that there is no
    with imprisonment for not less than one year nor proof of conspiracy since the
    more than ten years, perpetual disqualification Sandiganbayan itself stated that there is
    from public office, and confiscation or forfeiture no proof of actual agreement among the
    in favor of the Government of any prohibited accused to commit violations of RA
    interest and unexplained wealth manifestly out 3019.
    of proportion to his salary and other lawful  However, the Court held that conspiracy
    income.” in the case of the petitioner is not
    unfounded. The prosecution in all three
    cases was able to establish that Ecleo. Jr.
    and Navarra approved of overpayments
    made to Santillano.
     Ecleo and Navarra were parties to an
    agreement that approved disbursement
    of funds for a bogus municipal guest
    house and they could not come up with
    a plausible justification for such.
     Santillano, on the other hand, was
    indisputably on the receiving end of the
    overpayments and even issued receipts
    for them.
     All these undeniable circumstances lead
    to the logical conclusion that all three
    accused acted in a concerted effort to
    deprive the government of its much
    needed funds

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