People v. Sandiganbayan (2015)

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PEOPLE V. SANDIGANBAYAN
G.R. No. 160619 | September 09, 2015
SUMMARY: An Information was filed against Castillo (mayor of Bacoor, Cavite) charging him with vio-
lation of RA No. 3019, Section 3(e) due to the alleged illegal operation of the Villa Esperanza dumpsite. It
was alleged that he permitted it to operate without the requisite ECC and permit from the EMB. The San-
diganbayan granted Castillo’s Supplemental motion to Quash the information against him and the Court
ruled that the outright quashal was improper. The prosecution should have been given an opportunity to
correct the defect by amendment instead.
FACTS: This is a petition under Rule 45 of the Rules of Court seeks the reversal of the Resolutions by
Sandiganbayan, granting private respondent Castillo's Supplemental Motion to Dismiss the Information
filed against him and denying the subsequent Motion for Reconsideration.
Jessie B. Castillo was elected mayor of Bacoor, Cavite. An Information was filed against Castillo charg-
ing him with violation of Section 3(e) of RA No. 3019, in relation to the alleged illegal operation of the
Villa Esperanza dumpsite located in Molino, Bacoor, Cavite.
According to the Information, Castillo gave unwarranted benefits to his co-accused Melencio and Arciaga
by allowing the latter to operate the Villa Esperanza dumpsite without the requisite Environmental Com-
pliance Certificate (ECC) and permit from the Environmental Management Bureau (EMB).
Castillo filed a supplemental Motion to Quash the Information on the ground that the same does not charge
an offense. He claimed that a public officer may only be held liable for violation of Section 3(e) of R.A.
No. 3019 if he caused undue injury to the government or any private person and that such must be “speci-
fied, quantified and proven to the point of moral certainty.
The Ruling of the Sandiganbayan: granted Castillo’s Supplemental motion to Quash
The Sandiganbayan Fourth Division failed to decide unanimously on the Supplemental Motion. Thus, a
special division (composed of five Justices of the Sandiganbayan) was constituted.
The Sandiganbayan Special Division granted Castillo’s Supplemental motion to Quash and noted the fail-
ure of the information to quantify the alleged unwarranted benefits supposedly given by movant to his
co-accused as well as the undue injury caused to the residents and students of the area affected by the
dumpsite and agreed with the contention of Castillo. Motion for Reconsideration filed by People was
denied.
Castillo filed with the Sandiganbayan a Motion to Dismiss or Terminate Proceedings. He argued that the
case against him had been decriminalized by Section 37 of Republic Act No. 9003 and invoked the decision
of the CA absolving him of administrative liability. His motion was initially denied by the Sandiganbayan
in a Resolution dated September 6, 2001.
The Special Division also resolved, on November 3, 2003, to deny the motion for reconsideration subse-
quently filed by the People. Hence, this petition.
SC: reversed the Sandiganbayan’s ruling.
ISSUE: 1) WHETHER THE OUTRIGHT QUASHAL OF THE INFORMATION WAS PROPER. NO.
HELD:
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- Even assuming for the sake of argument that the Information was defective on the ground that the facts
charged therein do not constitute an offense, outright quashal of the Information is not the proper course
of action.
- Section 4, Rule 117 of the Rules of Court gives clear guidance on this matter. It provides:
Sec. 4. Amendment of complaint or information. -
If the motion to quash is based on an alleged defect of the complaint or information which can be
cured by amendment, the court shall order that an amendment be made.
- If it is based on the ground that the facts charged do not constitute an offense, the prosecution shall be
given by the court an opportunity to correct the defect by amendment. The motion shall be granted if the
prosecution fails to make the amendment, or the complaint or information still suffers from the same
defect despite the amendment.
- When a motion to quash is filed challenging the validity and sufficiency of an Information, and the defect
may be cured by amendment, courts must deny the motion to quash and order the prosecution to file an
amended Information.
- Generally, a defect pertaining to the failure of an Information to charge facts constituting an offense is
one that may be corrected by an amendment. In such instances, courts are mandated not to automatically
quash the Information; rather, it should grant the prosecution the opportunity to cure the defect through
an amendment.
- This rule allows a case to proceed without undue delay. By allowing the defect to be cured by simple
amendment, unnecessary appeals based on technical grounds, which only result to prolonging the pro-
ceedings, are avoided.
- More than this practical consideration, however, is the due process underpinnings of this rule. As ex-
plained by this Court in People v. Andrade, the State, just like any other litigant, is entitled to its day in
court. Thus, a court's refusal to grant the prosecution the opportunity to amend an Information, where
such right is expressly granted under the Rules of Court and affirmed time and again in a string of Su-
preme Court decisions, effectively curtails the State's right to due process.
- Hence, even assuming that the Information was defective, the Sandiganbayan should have first ordered
its amendment and not its quashal. Doing so would have saved the parties from resorting to an appeal to
this Court and this case from remaining in the docket of the Sandiganbayan for a long period.

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The Ruling of the Sandiganbayan: granted Castillo’s Supplemental motion to Quash

SC: reversed the Sandiganbayan’s ruling.

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