G.R. No. 238282 . April 26, 2022.
JOSEPH T. SORIANO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Joseph T. Soriano, a team member of the City Veterinary Office of Alaminos, Pangasinan, along with co-accused City Veterinarian Dr. Ronaldo B. Abarra, Meat Inspector Ryan R. Pagador, and Security Officer Lyndon R. Millan, were charged with violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The charge stemmed from an incident on April 17, 2009, where they flagged down and confiscated a delivery van owned by George T. Li, loaded with approximately 2,455 kilograms of meat and by-products worth around ₱250,000.00 from the San Vicente Dressing Plant (SVDP). The confiscation was based on alleged incomplete entries in the presented National Meat Inspection Service (NMIS) Certificate. The SVDP employees explained that the missing information was in the attached supporting documents, but the accused refused to accept this and impounded the van. The cargo was later unloaded and distributed to various government agencies. The Office of the Deputy Ombudsman recommended the filing of an Information, which was filed with the Sandiganbayan. Upon arraignment, petitioner and some co-accused pleaded not guilty. The Sandiganbayan, in its Decision dated January 19, 2018, found petitioner and his co-accused (except Pagador who was at large) guilty beyond reasonable doubt, sentencing them to imprisonment and ordering them to jointly and solidarily return the amount of ₱226,954.80. Petitioner filed a Petition for Review on Certiorari before the Supreme Court.

ISSUE

Whether the Sandiganbayan erred in finding petitioner Joseph T. Soriano guilty of violation of Section 3(e) of R.A. No. 3019 .

RULING

The Supreme Court denied the petition and affirmed the Sandiganbayan’s Decision. The Court held that all elements of violation of Section 3(e) of R.A. No. 3019 were present: (1) the accused are public officers; (2) the act was done in the discharge of their official, administrative, or judicial functions; (3) they acted with manifest partiality, evident bad faith, or gross inexcusable negligence; and (4) their action caused undue injury to any party, including the government, or gave any private party unwarranted benefits, advantage, or preference. The Court found that the accused acted with evident bad faith. The missing details in the NMIS certificate were minor and could have been easily verified from the attached documents, but the accused immediately confiscated the goods without proper verification. Their claim of acting pursuant to a city ordinance to prevent “hot meat” was not a valid justification for the confiscation, as the meat was from an accredited plant and covered by an NMIS certificate. The confiscation and subsequent distribution of the meat caused undue injury to SVDP. The defense of good faith was not available as their actions were precipitate and without legal basis. Petitioner, as part of the team, was found to have conspired with his co-accused in the commission of the offense.