BUENCAMINO VS.

PEOPLE

Facts:
 Edmundo Jose T. Buencamino, the former Mayor of San Miguel, Bulacan,
faced charges for violating Section 3(e) of Republic Act No. 3019, the Anti-
Graft and Corrupt Practices Act.
 Charges were due to the illegal imposition and collection of "pass way" fees
from Rosemoor Mining and Development Corporation (RMDC) (1,000 pesos
per truck) and impounding RMDC's trucks for non-payment.
 These fees were collected by Robert Tabarnero under Buencamino's
authorization.
 The Sangguniang Panlalawigan of Bulacan had already declared the
resolution authorizing these fees null and void.
 The Sandiganbayan found Buencamino guilty beyond reasonable doubt,
sentencing him to imprisonment and perpetual disqualification from public
office.
 Buencamino appealed to the Supreme Court, claiming the evidence was
inadmissible hearsay and the prosecution failed to prove his guilt beyond
reasonable doubt.

Issue:
1. Did the Sandiganbayan err in convicting Buencamino based on inadmissible
hearsay evidence?
2. Did the prosecution fail to prove Buencamino's guilt beyond reasonable
doubt?
3. Was Buencamino convicted for a manner of committing the offense not
alleged in the Informations, violating his right to be informed of the nature
of the accusation?

Ruling:
 The Supreme Court granted the petition, reversed and set aside the
Sandiganbayan's decision, and acquitted Buencamino of the charges.

Ratio:
 The Supreme Court found that the prosecution did not establish
Buencamino's guilt beyond reasonable doubt.
 Many pieces of documentary evidence presented were mere photocopies and
thus inadmissible as hearsay.
 Even if the documents were admitted, they did not prove Buencamino acted
with evident bad faith.
  Evident bad faith requires a fraudulent and dishonest purpose, which was
not shown in this case.
 There was a discrepancy between the mode of commission charged (evident
bad faith) and the one Buencamino was convicted of (gross inexcusable
negligence), violating his right to due process.
 Each modality of violating Section 3(e) of R.A. 3019 is distinct, and a charge
of one cannot lead to a conviction for another.
 Evidence indicated Buencamino acted based on an honest but erroneous
reliance on a defunct legal authority, not out of ill will or evident bad faith.
 The Court, therefore, acquitted Buencamino, upholding the constitutional
presumption of innocence.

BASAGAN VS. ESPINA

Facts:
 The case "Basagan v. Espina" involves an administrative complaint by Lorna
C. Basagan against Atty. Domingo P. Espina.
 Basagan accused Atty. Espina of violating Rule IV, Section 3(c) of A.M. No.
02-8-13-SC, related to notarial practice rules.
 Basagan, alleged that Atty. Espina notarized documents signed by his wife,
Mayor Rizalina B. Espina.
 The documents were related to a subsidiary loan agreement and contracts
for the Libagon Water System-Level III project.
 Basagan claimed these transactions were anomalous and the notarization
improper.
 The case was initially filed with the Ombudsman Visayas and later brought
to the Supreme Court.
 Despite multiple resolutions, Atty. Espina claimed he never received the
complaint due to mail delivery issues.
 The case was referred to the Integrated Bar of the Philippines (IBP) for
investigation.

Issue:
1. Did Atty. Domingo P. Espina violate Rule IV, Section 3(c) of A.M. No. 02-8-
13-SC by notarizing documents signed by his wife, Mayor Rizalina B.
Espina?
 Key Point: Whether Atty. Espina's notarization of documents signed
by his wife was a violation of notarial practice rules.
 2. Was there substantial evidence presented by Lorna C. Basagan to support
her claims against Atty. Espina?
 Key Point: Whether Basagan provided sufficient evidence to
substantiate her allegations.

Ruling:
 The Supreme Court dismissed the complaint against Atty. Domingo P.
Espina.
 Key Point: The dismissal was due to a lack of substantial evidence
presented by Lorna C. Basagan.

Ratio:
 The Court highlighted that the practice of law is a privilege with conditions,
requiring high standards of mental fitness and morality.
 Key Point: The burden of proof in disbarment or suspension cases lies with
the complainant.
 Basagan failed to provide original documents or certified true copies, relying
on photocopies, which are inadmissible under the Best Evidence Rule.
 Key Point: Photocopies are not acceptable evidence under the Best
Evidence Rule.
 The affidavit submitted by Basagan lacked specific details and was not based
on personal knowledge.
 Key Point: The affidavit was insufficient due to lack of specific details and
personal knowledge.
 The Court found the evidence insufficient to prove the alleged violation.
 Key Point: Insufficient evidence led to the presumption of innocence in
favor of Atty. Espina.
 Consequently, the complaint was dismissed.
 Key Point: The presumption of innocence resulted in the dismissal of the
complaint.

DE GUZMAN VS. COURT OF APPEALS

Facts:
 The case of De Guzman v. Court of Appeals (G.R. No. 110122) was decided on August
7, 1996.
 It involves a debt collection dispute between Celestina G. De Guzman (petitioner) and
spouses Cresenciano and Lucila De Guzman-Sioson (respondents).
  The Regional Trial Court (RTC) of Branch 29 in Cabanatuan City ruled in favor of the
respondents.
 The petitioner was ordered to pay P92,000 with 6% interest per annum from June 21,
1989, until fully paid, and P10,000 as attorney's fees.
 The respondents claimed the petitioner owed them P92,000, supported by a letter
presented as a photocopy in court.
 The petitioner denied the debt and claimed the letter was a forgery.
 The RTC's decision was affirmed by the Court of Appeals, leading the petitioner to seek
review by the Supreme Court.
 The petitioner and Lucila De Guzman-Sioson were sisters-in-law.
 Cresenciano claimed the petitioner managed a riceland jointly owned by Lucila and
Andres De Guzman but failed to deliver Lucila's share of the harvest.
 In May 1987, Cresenciano demanded delivery of 1,500 cavans of palay, and in July 1987,
he received a letter from the petitioner offering to settle the debt for P92,000.
 The petitioner did not pay, prompting the respondents to file a complaint in the RTC.
 The petitioner denied managing the farm, sending the letter, and being confronted by
Cresenciano about the letter.

Issue:
1. Did the lower court err in giving credence to the plaintiff's testimony that the defendant
acknowledged the payment of P92,000 as shown in Exhibit "C"?
2. Did the lower court err in believing the loss of the original of Exhibit "C"?
3. Did the lower court err in not dismissing the case and in not granting damages to the
defendant for the filing of a malicious and vindictive case, instead of granting damages to
the plaintiffs?

Ruling:
 The Supreme Court denied the petition for review and affirmed the decision of the Court
of Appeals.

Ratio:
 The Supreme Court emphasized that its jurisdiction is limited to reviewing errors of law,
not re-evaluating factual findings, especially when the Court of Appeals has affirmed the
trial court's findings in toto.
 The Court found no reason to disturb the factual findings of the lower courts.
1. The Court found that the lower courts correctly gave credence to the testimony of the
respondents. The petitioner's tendency to deny practically every allegation, even those
 involving undisputed collateral matters, rendered her testimony unworthy of belief. The
rule is that unsubstantiated denial is a negative and self-serving evidence with no weight
in law compared to the testimony of credible witnesses.
2. The Court found that the loss of the original letter was sufficiently explained by
Cresenciano, who testified that he misplaced it after having it photocopied. The due
execution of the document was proven during the trial through handwriting comparison,
and the photocopy was admitted as secondary evidence.
3. The Court held that the respondents' delay in filing the suit was justified by their attempts
to amicably settle the dispute, which is encouraged by law. The appellate court did not er
r in affirming the trial court's decision to admit the photocopy of the letter as evidence,
given the proven loss of the original and the due execution of the document.
 The Supreme Court concluded that the petitioner's claims were without merit and upheld
the decision of the Court of Appeals.