MEJORADA v.

SANDIGANBAYAN benefits, advantage or made on the basis of a the basis of the report and
G.R. Nos. L-51065-72/ JUNE 30, 1987/Cortes, J. /JPonce preference in the discharge document solely made by which eventually became
TOPIC Sec 3(h), elements, financial interest & intervenes in official capacity of his official administrative the Highway District the basis of payment. His
PETITIONERS Arturo A. Mejorada or judicial functions. Engineer to which petitioner contention that he had no
RESPONDENTS THE HONORABLE SANDIGANBAYAN And THE PEOPLE OF THE had no hand in preparing. participation is belied by the
PHILIPPINES fact that as a right-of-way
agent, his duty was
DOCTRINE. Section 3 which enumerates the crime punishable under RA 3019 applies to precisely to negotiate with
all public officers without distinction or qualification. Last sentence in 3(e) intended to property owners affected for
make clear the inclusions of officers and employees of officers or gov’t corporation which the purpose of
ordinarily may not come within the term. compensation.
The injury to any party, or He argues that for the 3rd There was evident bad faith
FACTS. giving any private party any element to be present, the on the part of the petitioner
1. Arturo Mejorada was employed as a Right of Way Agent in the Office of the Highway unwarranted benefits, alleged injury or damage to when he inflated the values
District Engineer in Pasig whose main duty was to negotiate with property owners affected advantage or preference was the complainants and the of the true claims and when
by highway constructions/improvements for the purpose of compensating them for the done through manifest, government must have been he divested the claimants of
damages incurred by said owners. partiality, evident bad faith caused by the public officer a large share of the amounts
2. Binangonan, Rizal residents were some of those affected by the widening of the Pasig-Sta or gross inexcusable in the discharge of his due them.
Cruz-Calamba Road. Mejorada contacted them and informed them that he could facilitate negligence. official, administrative or
their claims regarding the payment of the values of their lots and/or improvements affected judicial functions.
by the road widening. He required the claimants to sign blank copies of the “Sworn
Statement on the Correct and Fair Market Value of Real Properties” and “Agreement to
Demolish, Remove, and Reconstruct Improvements” then inflated the amounts. Likewise, DECISION.
the said “Agreements to Demolish” reflected the value of the improvements “as per
assessor” which on the average was only P2,000 lower than the value declared by the DENIED. Mejorada sentenced to 56 years, 8 days of imprisonment.
owners.
3. A few months after, he accompanied the claimants to collect from the Office of the
Highway District Engineer, to receive payments and personally assisted them in signing
the vouchers and enchasing the checks by certifying as to their identities and guaranteeing
payment.
4. Right after the claimants had received the proceeds of their checks, accused accompanied
them to his car where they were divested of the amounts paid to them, explaining that there
were many who would share in said amounts. All the claimants were helpless and unable
to complain because they were afraid of the accused and his armed companion.
5. The claimants filed 8 Informations against the petitioner.

ISSUES & RATIO.

WON Mejorada is liable under RA 3019, Sec 3(e) – YES.

Elements of Section 3(e)
The accused must be a
public officer.
That such public officer
caused undue injury to any
party, including the
Government, or gave any
private party unwarranted
Elements of 3(e) according
to Petitioner
The accused must be public
officer charged with the
duty of granting licenses or
permits or other
concessions.
[Same element] However,
he denies that there was
injury or damage caused to
the Government because the
payments were allegedly
What the Supreme Court
said
Its [sec. 3(e)] reference to
“any public officer” is
without distinction or
qualification and it specifies
the acts declared unlawful.
The government suffered
undue injury as a result of
the petitioner’s having
inflated the true claims of
complainants which became