CASE DIGEST : PATRIA C. GUTIERREZ VS. PEOPLE OF THE PHILIPPINES GR 193728 GAERLAN

 

[ G.R. No. 193728. October 13, 2021 ]

PATRIA C. GUTIERREZ, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS : After former Tiwi, Albay Mayor Naomi Corral’s death in 1996, her husband, Dr. Bernardo Corral, sought her gratuity pay. Despite GSIS approval of ₱352,456.11 and its inclusion in the 1997 municipal budget, newly elected Mayor Patria Gutierrez withheld payment, citing alleged financial irregularities by Municipal Treasurer Corazon Pulvinar. Gutierrez repeatedly reported Pulvinar to the Department of Finance and the Ombudsman for supposed anomalies, though investigations later found only minor administrative lapses. Despite confirmation from COA and municipal officials that the gratuity remained unpaid, Gutierrez refused to release the funds, claiming reliance on an audit stating otherwise. Dr. Corral later filed a complaint before the Sandiganbayan, accusing Gutierrez of violating Section 3(e) of R.A. 3019 (Anti-Graft and Corrupt Practices Act) for unjustly refusing payment and causing undue injury. The Sandiganbayan found Gutierrez guilty beyond reasonable doubt, ruling that she acted with evident bad faith in delaying the gratuity’s release despite clear entitlement and existing appropriations, sentencing her to 6 to 9 years’ imprisonment and perpetual disqualification from public office. Her motion for reconsideration was denied.

ISSUE : WON the SB erred in convicting Mayor Gutierrez

HELD : The Supreme Court ruled that Mayor Gutierrez’s petition lacked merit. It emphasized that under Rule 45, only questions of law may be reviewed, while factual findings of the Sandiganbayan are generally conclusive unless they fall under specific exceptions—which Gutierrez failed to show. Her claim that the lower court made “unfair inferences” did not qualify as grave abuse of discretion or factual misapprehension. Even assuming review was proper, the Court still upheld her conviction for violating Section 3(e) of R.A. No. 3019. It found that as Mayor of Tiwi, Albay, Gutierrez acted with evident bad faith when she unjustly withheld the gratuity pay of Dr. Corral despite the existence of all required clearances, appropriations, and approvals. Her repeated refusal to release payment showed a dishonest and malicious intent, causing undue injury to Dr. Corral’s family amounting to ₱352,456.11, which remains unpaid even after 25 years. Thus, the Court affirmed the Sandiganbayan’s decision in full.