Topic: TheThree-Fold Rule - Complex Crime

ARTURO A. MEJORADA v SANDIGANBAYAN (151 SCRA 399) June 30, 1987 GR No.
L51065-72

Facts:

n the period October 1977 to February 1978, the accused, being employed in the Office of the
Highway District Engineer, Pasig, Metro Manila as Right-of-Way-Agent, conspiring together
with two (2) other John Does, feloniously, directly intervene, work for, and facilitate the
approval of one Isagani de Leon's claim for the payment in the removal and reconstruction of his
house and a part of his land expropriated by the government having been affected by the
proposed Pasig-Sta.Cruz-Calamba Road, while Arturo A. Mejorada is in the discharge of his
official and after said claim was approved and the corresponding PNB Check was issued
and encashed in the amount of P7,200.00 give only P1.000.00 to claimant (Isagani de
deon), appropriating, applying and converting to themselves the amount of P6,200.00.

Issue:

Whether or not the essential elements constituting the offense penalized by section 3(e) of
Republic Act No. 3019, otherwise known as the Anti-Graft and Corrupt Practices Act have been
clearly and convincingly proven by the prosecution.

Ruling:

Yes.

Section 3 of Republic Act No. 3019 refers to “any public officer”. It makes no distinction or
qualification and specifies the acts declared unlawful. A violation may occur when an officer
takes advantage of his position and divests private parties of compensation they must receive.