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GR Nos. 195011-19

2013-09-30

DEL CASTILLO, J.

"A demurrer to the evidence is an objection by one of the parties in an action, to the effect that the evidence which his adversary produced is insufficient in point of law, whether true or not, to make out a case or sustain the issue. The party demurring challenges the sufficiency of the whole evidence to sustain a verdict. The court, in passing upon the sufficiency of the evidence raised in a demurrer, is merely required to ascertain whether there is competent or sufficient evidence to sustain the indictment or to support a verdict of guilt."[42]

GR No. 180418

2013-08-28

REPUBLIC v. LUZ REYES-BAKUNAWA

BERSAMIN, J.

Here, the Bakunawas filed a motion to dismiss, by which they specifically demurred to the evidence adduced against them. A demurrer to evidence is an objection by one of the parties in an action to the effect that the evidence that his adversary produced, whether true or not, is insufficient in point of law to make out a case or to sustain the issue. The demurring party thereby challenges the sufficiency of the whole evidence to sustain a judgment. The court, in passing upon the sufficiency of the evidence, is required merely to ascertain whether there is competent or sufficient evidence to sustain the indictment or claim, or to support a verdict of guilt or liability.[30]

GR No. 187340

2013-08-14

ANTONIO B. SANCHEZ v. PEOPLE

SERENO, C.J.

(1) The conclusion is a finding grounded entirely on speculation, surmise and conjectures; (2) The inference made is manifestly an error or founded on a mistake; (3) There is grave abuse of discretion; (4) The judgment is based on misapprehension of facts; and (5) The findings of fact are premised on want of evidence and are contradicted by evidence on record.[25] None of the foregoing circumstances is present. The findings of fact and conclusion of the Sandiganbayan that petitioner is guilty of violating Section 3(e), R.A. 3019 are sufficiently supported by the records.

GR No. 189343

2013-07-10

BENILDA N. BACASMAS v. SANDIGANBAYAN

SERENO, C.J.

The Information is sufficient, because it adequately describes the nature and cause of the accusation against petitioners,[64] namely the violation of the aforementioned law. The use of the three phrases "manifest partiality," "evident bad faith" and "inexcusable negligence" - in the same Information does not mean that three distinct offenses were thereby charged but only implied that the offense charged may have been committed through any of the modes provided by the law.[65] In addition, there was no inconsistency in alleging both the presence of conspiracy and gross inexcusable negligence, because the latter was not simple negligence. Rather, the negligence involved a willful, intentional, and conscious indifference to the consequences of one's actions or omissions.[66]

GR No. 171359

2012-07-18

BENJAMIN A. UMIPIG v. PEOPLE

VILLARAMA, JR., J.

The second element provides the different modes by which the crime may be committed, that is, through "manifest partiality," "evident bad faith," or "gross inexcusable negligence." There is "manifest partiality" when there is a clear, notorious, or plain inclination or predilection to favor one side or person rather than another.[57] "Evident bad faith" connotes not only bad judgment but also palpably and patently fraudulent and dishonest purpose to do moral obliquity or conscious wrongdoing for some perverse motive or ill will.[58] "Evident bad faith" contemplates a state of mind affirmatively operating with furtive design or with some motive of self-interest or ill will or for ulterior purposes.[59] "Gross inexcusable negligence" refers to negligence characterized by the want of even the slightest care, acting or omitting to act in a situation where there is a duty to act, not inadvertently but willfully and intentionally, with conscious indifference to consequences insofar as other persons may be affected.[60] These three modes are distinct and different from each other. Proof of the existence of any of these modes would suffice.[61]

GR Nos. 160243-52

2009-07-20

ROMEO D. LONZANIDA v. PEOPLE

LEONARDO-DE CASTRO, J.

The general rule is that the factual findings of the Sandiganbayan are conclusive upon this Court except where: (1) the conclusion is a finding grounded entirely on speculation, surmise and conjectures; (2) the inference made is manifestly an error or founded on a mistake; (3) there is grave abuse of discretion; (4) the judgment is based on misapprehension of facts; and (5) the findings of fact are premised on a want of evidence and are contradicted by evidence on record.[24]

GR Nos. 167860-65

2008-06-17

PEOPLE v. TEDDY M. PAJARO

YNARES-SATIAGO, J.

3.) that his action caused any undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage or preference in the discharge of his functions.[37]

GR No. 175930-31

2008-02-11

NICOLAS v. SANDIGANBAYAN

CARPIO MORALES, J.

A demurrer to evidence is an objection by one of the parties in an action to the effect that the evidence which his adversary produced is insufficient in point of law to make out a case or sustain the issue.[38]

GR NO. 150194

2007-03-06

ROBERT TAYABAN Y CALIPLIP v. PEOPLE

AUSTRIA-MARTINEZ, J.

In the present case, it cannot be gainsaid that the destruction of the five concrete posts and the other improvements in the construction of the Tinoc public market is clear and substantial evidence to prove that the Government suffered undue injury. Under prevailing jurisprudence, proof of the extent or quantum of damage is not essential, it being sufficient that the injury suffered or benefits received can be perceived to be substantial enough and not merely negligible.[38]

GR NO. 155574

2006-11-20

TIMOTEO A. GARCIA v. SANDIGANBAYAN

CHICO-NAZARIO, J.

Factual findings of the Sandiganbayan are conclusive upon this Court except where: (1) the conclusion is a finding grounded entirely on speculation, surmise and conjectures; (2) the inference made is manifestly an error or founded on a mistake; (3) there is grave abuse of discretion; (4) the judgment is based on misapprehension of facts; and (5) the findings of fact are premised on a want of evidence and are contradicted by evidence on record.[29] In the case before us, we are constrained to apply the exception rather than the rule. We find that the ruling of the Sandiganbayan that petitioners actually received the vehicles through his representatives is grounded entirely on speculation, surmise, and conjectures, and not supported by evidence on record. The certainty of petitioner's receipt of the vehicle for his alleged personal use was not substantiated.

GR No. 156643

2006-06-27

FRANCISCO SALVADOR B. ACEJAS III v. PEOPLE

PANGANIBAN, C.J.

the Sandiganbayan needed to act upon.[72] Finally we reiterate that, as a rule, factual findings of the Sandiganbayan are conclusive upon this Court.[73] We are convinced that these were clearly based on the evidence adduced in this case.

	GR Nos. 195011-19 2013-09-30	GREGORIO SINGIAN v. SANDIGANBAYAN DEL CASTILLO, J.
"A demurrer to the evidence is an objection by one of the parties in an action, to the effect that the evidence which his adversary produced is insufficient in point of law, whether true or not, to make out a case or sustain the issue. The party demurring challenges the sufficiency of the whole evidence to sustain a verdict. The court, in passing upon the sufficiency of the evidence raised in a demurrer, is merely required to ascertain whether there is competent or sufficient evidence to sustain the indictment or to support a verdict of guilt."[42]
	GR No. 180418 2013-08-28	REPUBLIC v. LUZ REYES-BAKUNAWA BERSAMIN, J.
Here, the Bakunawas filed a motion to dismiss, by which they specifically demurred to the evidence adduced against them. A demurrer to evidence is an objection by one of the parties in an action to the effect that the evidence that his adversary produced, whether true or not, is insufficient in point of law to make out a case or to sustain the issue. The demurring party thereby challenges the sufficiency of the whole evidence to sustain a judgment. The court, in passing upon the sufficiency of the evidence, is required merely to ascertain whether there is competent or sufficient evidence to sustain the indictment or claim, or to support a verdict of guilt or liability.[30]
	GR No. 187340 2013-08-14	ANTONIO B. SANCHEZ v. PEOPLE SERENO, C.J.
(1) The conclusion is a finding grounded entirely on speculation, surmise and conjectures; (2) The inference made is manifestly an error or founded on a mistake; (3) There is grave abuse of discretion; (4) The judgment is based on misapprehension of facts; and (5) The findings of fact are premised on want of evidence and are contradicted by evidence on record.[25] None of the foregoing circumstances is present. The findings of fact and conclusion of the Sandiganbayan that petitioner is guilty of violating Section 3(e), R.A. 3019 are sufficiently supported by the records.
	GR No. 189343 2013-07-10	BENILDA N. BACASMAS v. SANDIGANBAYAN SERENO, C.J.
The Information is sufficient, because it adequately describes the nature and cause of the accusation against petitioners,[64] namely the violation of the aforementioned law. The use of the three phrases "manifest partiality," "evident bad faith" and "inexcusable negligence" - in the same Information does not mean that three distinct offenses were thereby charged but only implied that the offense charged may have been committed through any of the modes provided by the law.[65] In addition, there was no inconsistency in alleging both the presence of conspiracy and gross inexcusable negligence, because the latter was not simple negligence. Rather, the negligence involved a willful, intentional, and conscious indifference to the consequences of one's actions or omissions.[66]
	GR No. 171359 2012-07-18	BENJAMIN A. UMIPIG v. PEOPLE VILLARAMA, JR., J.
The second element provides the different modes by which the crime may be committed, that is, through "manifest partiality," "evident bad faith," or "gross inexcusable negligence." There is "manifest partiality" when there is a clear, notorious, or plain inclination or predilection to favor one side or person rather than another.[57] "Evident bad faith" connotes not only bad judgment but also palpably and patently fraudulent and dishonest purpose to do moral obliquity or conscious wrongdoing for some perverse motive or ill will.[58] "Evident bad faith" contemplates a state of mind affirmatively operating with furtive design or with some motive of self-interest or ill will or for ulterior purposes.[59] "Gross inexcusable negligence" refers to negligence characterized by the want of even the slightest care, acting or omitting to act in a situation where there is a duty to act, not inadvertently but willfully and intentionally, with conscious indifference to consequences insofar as other persons may be affected.[60] These three modes are distinct and different from each other. Proof of the existence of any of these modes would suffice.[61]
	GR Nos. 160243-52 2009-07-20	ROMEO D. LONZANIDA v. PEOPLE LEONARDO-DE CASTRO, J.
The general rule is that the factual findings of the Sandiganbayan are conclusive upon this Court except where: (1) the conclusion is a finding grounded entirely on speculation, surmise and conjectures; (2) the inference made is manifestly an error or founded on a mistake; (3) there is grave abuse of discretion; (4) the judgment is based on misapprehension of facts; and (5) the findings of fact are premised on a want of evidence and are contradicted by evidence on record.[24]
	GR Nos. 167860-65 2008-06-17	PEOPLE v. TEDDY M. PAJARO YNARES-SATIAGO, J.
3.) that his action caused any undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage or preference in the discharge of his functions.[37]
	GR No. 175930-31 2008-02-11	NICOLAS v. SANDIGANBAYAN CARPIO MORALES, J.
A demurrer to evidence is an objection by one of the parties in an action to the effect that the evidence which his adversary produced is insufficient in point of law to make out a case or sustain the issue.[38]
	GR NO. 150194 2007-03-06	ROBERT TAYABAN Y CALIPLIP v. PEOPLE AUSTRIA-MARTINEZ, J.
In the present case, it cannot be gainsaid that the destruction of the five concrete posts and the other improvements in the construction of the Tinoc public market is clear and substantial evidence to prove that the Government suffered undue injury. Under prevailing jurisprudence, proof of the extent or quantum of damage is not essential, it being sufficient that the injury suffered or benefits received can be perceived to be substantial enough and not merely negligible.[38]
	GR NO. 155574 2006-11-20	TIMOTEO A. GARCIA v. SANDIGANBAYAN CHICO-NAZARIO, J.
Factual findings of the Sandiganbayan are conclusive upon this Court except where: (1) the conclusion is a finding grounded entirely on speculation, surmise and conjectures; (2) the inference made is manifestly an error or founded on a mistake; (3) there is grave abuse of discretion; (4) the judgment is based on misapprehension of facts; and (5) the findings of fact are premised on a want of evidence and are contradicted by evidence on record.[29] In the case before us, we are constrained to apply the exception rather than the rule. We find that the ruling of the Sandiganbayan that petitioners actually received the vehicles through his representatives is grounded entirely on speculation, surmise, and conjectures, and not supported by evidence on record. The certainty of petitioner's receipt of the vehicle for his alleged personal use was not substantiated.
	GR No. 156643 2006-06-27	FRANCISCO SALVADOR B. ACEJAS III v. PEOPLE PANGANIBAN, C.J.
the Sandiganbayan needed to act upon.[72] Finally we reiterate that, as a rule, factual findings of the Sandiganbayan are conclusive upon this Court.[73] We are convinced that these were clearly based on the evidence adduced in this case.

FLORANTE SORIQUEZ v. SANDIGANBAYAN