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