ENGR. RICARDO L. SANTILLANO v. PEOPLE, GR Nos.

175045-46, 2010-03-03
ENGR. RICARDO L. SANTILLANO, Petitioner, vs. PEOPLE OF THE
PHILIPPINES, Respondent.

Facts
Engr. Ecleo appealed the judgment holding him guilty of three counts of violation of
Sec 3a of RA 3019 or the Anti-Graft and Corrupt Practices in criminal case nos.
24467, 24468 and 24469.

(1) In Criminal Case No. 24467, the Court finds the accused Ruben B. Ecleo, Jr.,
Anadelia Naluan Navarra and Ricardo L. Santillano GUILTY beyond reasonable
doubt of violation of Section 3(e) of Republic Act No. 3019 and they are each
sentenced to suffer the penalty of imprisonment of six (6) years and one (1) month to
ten (10) years and six (6) months. In addition, they shall each suffer the penalty of
perpetual disqualification from public office. They are likewise ordered to return,
jointly and solidarily, to the municipality of San Jose, Surigao del Norte the amount of
P444,575.17.
(2) In Criminal Case No. 24468, the Court finds the accused Ruben B. Ecleo, Jr.,
Anadelia Naluan Navarra and Ricardo L. Santillano GUILTY beyond reasonable
doubt of violation of Section 3(e) of Republic Act No. 3019 and they are each
sentenced to suffer the penalty of imprisonment of six (6) years and one (1) month to
ten (10) years and six (6) months. In addition, they shall each suffer the penalty of
perpetual disqualification from public office. They are likewise ordered to return,
jointly and solidarily, to the municipality of San Jose, Surigao del Norte the amount of
P2,412,639.70.
(3) In Criminal Case No. 24469, the Court finds the accused Ruben B. Ecleo, Jr.,
GUILTY beyond reasonable doubt of violation of Section 3(e) of Republic Act No.
3019 and he is hereby sentenced to suffer the penalty of imprisonment of six (6) years
and one (1) month to ten (10) years and six (6) months and to suffer perpetual
disqualification from public office.

Issue
Whether or not only public officers can be convicted under RA 3019.

Ruling
No. Even the private persons can be held liable under RA 3019. While Santillano
asserted that the Sandigan bayan allegedly inserted an additional phrase to the law in
order to have a legal basis in holding him liable, the Court dismissed this without
merit

Penera, Hyacinth Anne H.

Section 1b