In Demie L. Uriarte v. People of the Philippines, the Supreme Court affirmed the conviction of a municipal assessor for violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The assessor was found guilty of causing undue injury by altering tax declarations to favor himself and his family, thereby prejudicing the rights of another party. This case clarifies the responsibilities of public officials in handling property documents and underscores the potential for criminal liability when such actions lead to harm.

When Public Duty Turns to Personal Gain: Examining Official Misconduct in Uriarte

The case revolves around Demie L. Uriarte, the Municipal Assessor of Carrascal, Surigao del Sur, who made alterations to tax declarations concerning properties belonging to Joventino Correos and Uriarte’s own father, Antioco Uriarte. The changes, specifically regarding property location and boundaries, were deemed to favor Uriarte’s interests at the expense of Correos’ heirs. This prompted Evelyn Arpilleda, one of Correos’ heirs, to file a complaint, leading to Uriarte’s conviction under Section 3(e) of R.A. 3019. The central legal question is whether Uriarte’s actions constituted a violation of the Anti-Graft and Corrupt Practices Act, warranting criminal liability.

Section 3(e) of R.A. 3019 addresses corrupt practices by public officers, stating that it is unlawful for an officer to cause undue injury to any party or give unwarranted benefits, advantage, or preference through manifest partiality, evident bad faith, or gross inexcusable negligence. The elements of this crime are well-established in Philippine jurisprudence. First, the accused must be a public officer performing administrative, judicial, or official functions. Second, the officer must have acted with manifest partiality, evident bad faith, or inexcusable negligence. Finally, the officer’s actions must have caused undue injury to any party, including the government, or given any private party unwarranted benefits, advantage, or preference.

In Uriarte’s case, the Information filed against him sufficiently alleged all the elements of the offense. The Information stated that Uriarte, as a public officer, acted with evident bad faith and manifest partiality by changing the location and boundaries of Joventino Correos’ property to favor his own interests, thus causing damage and prejudice to Correos’ heirs. The alteration of the tax declarations was the prohibited act, while the element of undue injury was alleged in the phrase “to the damage and prejudice of the said heirs.”

The Supreme Court, in its analysis, emphasized that Section 3(e) of R.A. 3019 can be committed either through dolo (evident bad faith or manifest partiality) or culpa (gross inexcusable negligence). Manifest partiality exists when there is a clear inclination to favor one side or person over another. Evident bad faith connotes a palpably fraudulent and dishonest purpose or ill will. Gross inexcusable negligence refers to negligence characterized by a want of even the slightest care, acting or omitting to act willfully and intentionally, with conscious indifference to consequences.

The evidence presented during trial revealed that Uriarte acted with evident bad faith in altering the tax declarations. He admitted to making the changes but attempted to justify his actions by citing the General Instructions for the general revision of tax declarations. However, the Court found that Uriarte was aware of the consequences of altering the entries, especially in untitled properties, and that his failure to inform Joventino Correos or the private complainant of the alterations further strengthened the finding of bad faith. Even if Uriarte’s actions were not motivated by ill will but were merely a mistake in interpreting the Instructions, his conduct could still be considered inexcusable negligence.

Paragraph 28 of the General Instructions Governing the Conduct and Procedures in the General Revision of Real Property Assessments provides guidelines on how boundaries should be indicated:

28) The boundaries which will appear in the field sheets shall be the name of persons, streets, rivers or natural boundaries adjoining the property subject of revision. The technical descriptions of the land to be revised should not be written down on the field sheets, not only to follow the prescribed form but also to avoid additional or unnecessary typing costs. Tax declarations are issued for taxation purposes and they are not titles to lands. In case boundary conflict arises, the parties can refer to the titles.

This instruction makes it clear that the designation of boundaries is not limited to the names of persons but can include streets, rivers, and natural boundaries. Uriarte’s assertion that boundaries should only be designated by the names of landowners was, therefore, a misinterpretation of the guidelines, indicative of either bad faith or gross negligence.

Another critical aspect of the case is the element of undue injury. Section 3(e) of R.A. 3019 can be violated either by causing undue injury to any party or by giving any private party unwarranted benefit, advantage, or preference. These are two different modes of committing the offense. Undue injury is consistently interpreted as actual damage, meaning any wrong or damage done to another in their person, rights, reputation, or property. Unwarranted benefit means lacking adequate or official support; unjustified; unauthorized; or without justification or adequate reasons. Advantage means a more favorable or improved position or condition; benefit or gain of any kind. Preference signifies priority or higher evaluation or desirability; choice or estimation above another.

The Supreme Court affirmed the Sandiganbayan’s finding that Uriarte’s actions caused undue injury to private complainant and gave himself unwarranted benefit. The alteration of the boundaries of the property substantially changed the identity of the property, especially since the property was untitled and no survey had been conducted. Tax declarations, in such cases, constitute important evidence of possession and ownership. The alterations made by Uriarte made it appear that his property was between the Carrascal River and that of the private complainant, effectively lessening the area of the private complainant’s property.

Even though Uriarte later restored the original entries in the tax declarations, the Supreme Court held that this did not extinguish his criminal liability. The Court emphasized that restoration of the entries is not one of the ways to extinguish criminal liability under Article 89 of the Revised Penal Code, which applies in a suppletory character as provided for under Article 10 of the same Code.

The defense argued that Uriarte could not be convicted based on the conclusion of land-grabbing and dispossession, as such facts were not alleged in the information. However, the Supreme Court clarified that Uriarte was charged and convicted of violating Section 3(e), R.A. 3019, not for dispossession of property. The finding of the RTC that Uriarte had a hidden intention to grab and dispossess private complainant was merely descriptive of how he acted with evident bad faith, which need not be further alleged in the information.

The Court reiterated that an information needs only to allege the acts or omissions constituting the offense. It must state only the relevant facts, as the reasons can be proven during trial. An allegation of evident bad faith on the part of Uriarte was sufficient, and the trial court correctly found that his intention to grab the land of private complainant was a manifestation of evident bad faith.

In conclusion, the Supreme Court upheld the conviction of Demie L. Uriarte for violating Section 3(e) of R.A. 3019, finding that he acted with evident bad faith in altering tax declarations to favor himself, thereby causing undue injury to private complainant. The Court emphasized that public officials must exercise utmost care and diligence in the performance of their duties and that any act of manifest partiality, evident bad faith, or gross inexcusable negligence that causes undue injury to others will be met with the full force of the law.

FAQs

What was the key issue in this case?	The key issue was whether the municipal assessor violated Section 3(e) of R.A. 3019 by altering tax declarations in a way that caused undue injury to another party and benefited himself. The Supreme Court upheld the conviction.
What is Section 3(e) of R.A. 3019?	Section 3(e) of R.A. 3019, also known as the Anti-Graft and Corrupt Practices Act, prohibits public officials from causing undue injury to any party or giving unwarranted benefits through manifest partiality, evident bad faith, or gross inexcusable negligence. This law aims to prevent corrupt practices in government.
What are the elements of a violation of Section 3(e) of R.A. 3019?	The elements are: (1) the accused is a public officer, (2) the officer acted with manifest partiality, evident bad faith, or inexcusable negligence, and (3) the actions caused undue injury to any party or gave unwarranted benefits. All elements must be proven for a conviction.
What constitutes “undue injury” under the law?	“Undue injury” refers to actual damage or harm suffered by a party as a result of the public officer’s actions. It includes any wrong or damage done to another in their person, rights, reputation, or property.
What is the role of tax declarations in property disputes?	Tax declarations are indicative of a claim of ownership or possession, though they are not conclusive evidence. Coupled with proof of actual possession, they can be the basis of a claim for ownership, especially for untitled properties.
Did the restoration of the original entries in the tax declarations affect the criminal liability?	No, the restoration of the original entries did not extinguish the criminal liability. The Court stated that such restoration is not one of the ways to extinguish criminal liability under the Revised Penal Code.
What was the penalty imposed on the accused?	The accused was sentenced to an indeterminate prison term of six (6) years and one (1) month, as minimum, to ten (10) years and one (1) day, as maximum, with perpetual disqualification from public office. This aligns with the penalties prescribed under R.A. 3019.
Can a public official be held liable for mere negligence under Section 3(e) of R.A. 3019?	Yes, a public official can be held liable for gross inexcusable negligence if their actions or omissions cause undue injury or give unwarranted benefits. The law covers both intentional and negligent acts.

The Uriarte case serves as a stark reminder of the responsibilities entrusted to public officials and the serious consequences of abusing their positions. By manipulating property records, the assessor violated the public’s trust and caused tangible harm, leading to a just conviction. This case reinforces the importance of integrity and accountability in public service.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: DEMIE L. URIARTE, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT., G.R. NO. 169251, December 20, 2006