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DEMETRIO R. TECSON v. SANDIGANBAYAN

This case has been cited 11 times or more.

	GR No. 183445 2011-09-14	OFFICE OF PRESIDENT v. CALIXTO R. CATAQUIZ MENDOZA, J.
It is a basic rule in administrative law that public officials are under a three-fold responsibility for a violation of their duty or for a wrongful act or omission, such that they may be held civilly, criminally and administratively liable for the same act.[37] Obviously, administrative liability is separate and distinct from penal and civil liability.[38] In the case of People v. Sandiganbayan,[39]the Court elaborated on the difference between administrative and criminal liability: The distinct and independent nature of one proceeding from the other can be attributed to the following: first, the difference in the quantum of evidence required and, correlatively, the procedure observed and sanctions imposed; and second, the principle that a single act may offend against two or more distinct and related provisions of law, or that the same act may give rise to criminal as well as administrative liability.[40]
	GR No. 170146 2011-06-08	WALDO Q. FLORES v. ATTY. ANTONIO F. MONTEMAYOR VILLARAMA, JR., J.
The same wrongful act committed by the public officer can subject him to civil, administrative and criminal liabilities. We held in Tecson v. Sandiganbayan[5]: [I]t is a basic principle of the law on public officers that a public official or employee is under a three-fold responsibility for violation of duty or for a wrongful act or omission. This simply means that a public officer may be held civilly, criminally, and administratively liable for a wrongful doing. Thus, if such violation or wrongful act results in damages to an individual, the public officer may be held civilly liable to reimburse the injured party. If the law violated attaches a penal sanction, the erring officer may be punished criminally. Finally, such violation may also lead to suspension, removal from office, or other administrative sanctions. This administrative liability is separate and distinct from the penal and civil liabilities. (Italics in the original.)
	GR No. 159132 2008-12-18	FE CAYAO-LASAM v. SPS. CLARO AND EDITHA RAMOLETE AUSTRIA-MARTINEZ, J.
For one, the principle of double jeopardy finds no application in administrative cases. Double jeopardy attaches only: (1) upon a valid indictment; (2) before a competent court; (3) after arraignment; (4) when a valid plea has been entered; and (5) when the defendant was acquitted or convicted, or the case was dismissed or otherwise terminated without the express consent of the accused.[25] These elements were not present in the proceedings before the Board of Medicine, as the proceedings involved in the instant case were administrative and not criminal in nature. The Court has already held that double jeopardy does not lie in administrative cases.[26]
	GR No. 168309 2008-09-25	OFFICE OF OMBUDSMAN v. MARIAN D. TORRES NACHURA, J.
Likewise, it is a well-entrenched jurisprudential principle that the dismissal of the criminal case involving the same set of facts does not automatically result in the dismissal of the administrative charges against private respondents.[8]
	GR NO. 166038 2007-12-04	TRINIDAD v. OFFICE OF THE OMBUDSMAN CARPIO MORALES, J.
Res judicata is a doctrine of civil law and thus has no bearing on criminal proceedings.[15]
	GR NO. 169801 2007-09-11	REPUBLIC v. DONATILLA R. BAUTISTA TINGA, J.
The Court of Appeals sweepingly brushed aside Liangco's testimony and was persuaded by Macabulos' rebuttal testimony denying that she had spoken to Liangco about the incident. The rule is that the positive and categorical assertions of witnesses generally prevail over bare denials. Such accordance of greater probative value to evidence that is positive in nature than that which is negative in character is a time-honored principle.[20] Denial is a self-serving negative evidence that cannot be given greater weight than the declaration of credible witnesses who testified on affirmative matters. [21] Accordingly, Liangco's testimony that he was informed about the incident must be upheld.
	GR Nos. 146368-69 2003-10-23	MADELEINE MENDOZA-ONG v. SANDIGANBAYAN QUISUMBING, J.
Based on the foregoing, the elements of the offense charged in the assailed information are as follows: (1) the offender is a public officer; (2) he has secured or obtained, or would secure or obtain, for a person any government permit or license; (3) he directly or indirectly requested or received from said person any gift, present or other pecuniary or material benefit for himself or for another; and (4) he requested or received the gift, present or other pecuniary or material benefit in consideration for help given or to be given.[16]
	GR No. 139400 2003-09-03	PEOPLE v. MAURICIO WATIWAT SANDOVAL-GUTIERREZ, J.
Moreover, firmly established is the rule that alibi and denial are inherently weak and have always been viewed with disfavor by the courts due to the facility with which they can be concocted.[22] Such defense warrants the least credibility or none at all[23] and cannot prevail over the positive identification of the accused by the prosecution witness.[24] Denial is a self-serving negative evidence that cannot be given greater weight than the declaration of a credible witness who testified on affirmative matters.[25]