MEJORADA VS SANDIGANBAYAN

FACTS:

Arturo Mejorada was found guilty beyond reasonable doubt of violating Section3(E) of RA. 3019, aka
Anti-Graft and Corrupt Practices Act. Mejorada was a right-away agent whose duty was to process the
claims for compensation of damages of property owners affected by highway construction
and improvements. He required the claimants to sign blank copies of Sworn Statements and
Agreements to Demolish, where it appeared that the properties of the claimants have higher values
than the actual value being claimed by them. However, the claimants did not bother reading through
the paper because they very much interested in the compensation of damages. After processing the
claims, instead of giving to the claimants the proper amount, Mejorada gave one of them Php 5,000 and
the rest, Php 1,000 each, saying that there are many who would share in said amounts. The claimants
weren’t able to complain because they were afraid of the accused and his armed companion. The
Sandiganbayan sentenced Mejorada 56 years and8 years of imprisonment which is equivalent to the
eight (8) penalties for the eight (8) informations filed against him. Contention of the State: Section 3 of
RA 3019 states that Mejorada should be punished with “imprisonment for not less than 1 year nor more
than 10 years” as stated in Sec 9 of the same Act. In this case, there are 8 charges against him and each
charge should be served with the penalty prescribed by the law. Contention of the Accused: Mejorada
states that the penalty imposed upon him is contrary to the three-fold rule and states that the duration
should not exceed 40years. This is in accordance to Article 70 of the RPC.

ISSUE: WON the penalty imposed upon him violates the three-fold rule under Article 70 of the RPC.

RULING: The Court favors the State. Article 70 of the RPC does not state anything aboutthe “imposition
of penalty”. It only explains the “service” of sentence, “duration”of penalty and penalty “to be inflicted”.
It should be interpreted that the
accusedcannot be made to serve more than three times the most severe of thesepenalties the
maximum of which is forty (40) years. As stated in a previous case, “The courts can still impose as many
penalties as there are separate and distinct offenses committed, since for every individual crime
committed, a
correspondingpenalty is prescribed by law.” With these reasons, Mejorada cannot correctlycontend that
his penalty is excessive. There are eight charges against him and each has an equivalent penalty as
prescribed by RA 3019, thus, Sandiganbayan has imposed the correct penalty.