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GR No. 160619

2015-09-09

JARDELEZA, J.

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.[26]

GR No. 211703

2014-12-10

EDELBERT C. UYBOCO v. PEOPLE

VELASCO JR., J.

3) That his action caused undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage or preference in the discharge of his functions.[8]

GR No. 175750-51

2014-04-02

SILVERINA E. CONSIGNA v. PEOPLE

PEREZ, J.

In this case, petitioner was charged of violating Sec. 3(e) of R.A. No. 3019 under the alternative mode of "causing undue injury" to Moleta committed with evident bad faith, for which she was correctly found guilty. "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. "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,[36] which manifested in petitioner's actuations and representation.

GR No. 187268

2013-09-04

JOVITO C. PLAMERAS v. PEOPLE

PEREZ, J.

1) The accused must be a public officer discharging administrative, judicial or official functions; 2) He must have acted with manifest partiality, evident bad faith or gross inexcusable negligence; and 3) That his action caused undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage or preference in the discharge of his functions.[43] We focus on the next elements, there being no dispute that the first element of the offense is present.

GR No. 171671

2012-06-18

PEOPLE v. ARISTEO E. ATIENZA

PERALTA, J.

3. His action caused any undue injury to any party, including the government, or gave any private party unwarranted benefits, advantage or preference in the discharge of his functions.[20]

GR No. 160933

2010-11-24

NICEAS M. BELONGILOT v. ROLANDO S. CUA

BRION, J.

In Uriarte v. People,[30] this Court explained that "Section 3(e) of R.A. 3019 may be committed either by dolo, as when the accused acted with evident bad faith or manifest partiality, or by culpa, as when the accused committed 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. `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. It contemplates a state of mind affirmatively operating with furtive design or with some motive or self-interest or ill will or for ulterior purposes. `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."[31] In issuing the TRO and preliminary injunction, and accepting Constantino's appeal, the respondents demonstrated manifest partiality, evident bad faith, and gross inexcusable negligence, which, oddly enough, the Ombudsman failed to take into consideration in determining the existence of probable cause.[32]

GR No. 177429

2009-11-24

ANICIA VALDEZ-TALLORIN v. HEIRS OF JUANITO TARONA

ABAD, J.

The Court cannot discount the importance of tax declarations to the persons in whose names they are issued. Their cancellation adversely affects the rights and interests of such persons over the properties that the documents cover. The reason is simple: a tax declaration is a primary evidence, if not the source, of the right to claim title of ownership over real property, a right enforceable against another person. The Court held in Uriarte v. People[19] that, although not conclusive, a tax declaration is a telling evidence of the declarant's possession which could ripen into ownership.

GR No. 164015

2009-02-26

RAMON A. ALBERT v. SANDIGANBAYAN

CARPIO, J.

This crime has the following essential elements:[19]

GR No. 145184

2008-03-14

PRESIDENTIAL AD HOC FACT-FINDING COMMITTEE ON BEHEST LOANS v. ANIANO A. DESIERTO

NACHURA, J.

For one to have violated Section 3(e) of R.A. No. 3019, the following elements must be established: 1) the accused must be a public officer discharging administrative, judicial or official functions; 2) he must have acted with manifest partiality, evident bad faith or inexcusable negligence; and 3) he must have caused undue injury to any party, including the government, or given any private party unwarranted benefits, advantage or preference, in the discharge of his functions.[18] Evidently, mere bad faith or partiality and negligence per se are not enough for one to be held liable under the law. It is required that the act constitutive of bad faith or partiality must, in the first place, be evident or manifest, while the negligent deed should be both gross and inexcusable. Further, it is necessary to show that any or all of these modalities resulted in undue injury to a specified party.[19]

GR NOS. 167006-07

2007-08-14

DANILO D. COLLANTES v. SIMEON MARCELO

NACHURA, J.

The elements of the offense are: 1) the accused must be a public officer discharging administrative, judicial or official functions; 2) he must have acted with manifest partiality, evident bad faith or inexcusable negligence; and 3) that his action caused any undue injury to any party, including the government, or gave any private party unwarranted benefits, advantage or preference in the discharge of his functions.[27] Evidently, mere bad faith or partiality and negligence per se are not enough for one to be held liable under the law, since the act constitutive of bad faith or partiality must, in the first place, be evident or manifest, respectively, while the negligent deed should be both gross and inexcusable. It is further required that any or all of these modalities ought to result in undue injury to a specified party.[28]

	GR No. 160619 2015-09-09	PEOPLE v. SANDIGANBAYAN JARDELEZA, J.
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.[26]
	GR No. 211703 2014-12-10	EDELBERT C. UYBOCO v. PEOPLE VELASCO JR., J.
3) That his action caused undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage or preference in the discharge of his functions.[8]
	GR No. 175750-51 2014-04-02	SILVERINA E. CONSIGNA v. PEOPLE PEREZ, J.
In this case, petitioner was charged of violating Sec. 3(e) of R.A. No. 3019 under the alternative mode of "causing undue injury" to Moleta committed with evident bad faith, for which she was correctly found guilty. "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. "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,[36] which manifested in petitioner's actuations and representation.
	GR No. 187268 2013-09-04	JOVITO C. PLAMERAS v. PEOPLE PEREZ, J.
1) The accused must be a public officer discharging administrative, judicial or official functions; 2) He must have acted with manifest partiality, evident bad faith or gross inexcusable negligence; and 3) That his action caused undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage or preference in the discharge of his functions.[43] We focus on the next elements, there being no dispute that the first element of the offense is present.
	GR No. 171671 2012-06-18	PEOPLE v. ARISTEO E. ATIENZA PERALTA, J.
3. His action caused any undue injury to any party, including the government, or gave any private party unwarranted benefits, advantage or preference in the discharge of his functions.[20]
	GR No. 160933 2010-11-24	NICEAS M. BELONGILOT v. ROLANDO S. CUA BRION, J.
In Uriarte v. People,[30] this Court explained that "Section 3(e) of R.A. 3019 may be committed either by dolo, as when the accused acted with evident bad faith or manifest partiality, or by culpa, as when the accused committed 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. `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. It contemplates a state of mind affirmatively operating with furtive design or with some motive or self-interest or ill will or for ulterior purposes. `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."[31] In issuing the TRO and preliminary injunction, and accepting Constantino's appeal, the respondents demonstrated manifest partiality, evident bad faith, and gross inexcusable negligence, which, oddly enough, the Ombudsman failed to take into consideration in determining the existence of probable cause.[32]
	GR No. 177429 2009-11-24	ANICIA VALDEZ-TALLORIN v. HEIRS OF JUANITO TARONA ABAD, J.
The Court cannot discount the importance of tax declarations to the persons in whose names they are issued. Their cancellation adversely affects the rights and interests of such persons over the properties that the documents cover. The reason is simple: a tax declaration is a primary evidence, if not the source, of the right to claim title of ownership over real property, a right enforceable against another person. The Court held in Uriarte v. People[19] that, although not conclusive, a tax declaration is a telling evidence of the declarant's possession which could ripen into ownership.
	GR No. 164015 2009-02-26	RAMON A. ALBERT v. SANDIGANBAYAN CARPIO, J.
This crime has the following essential elements:[19]
	GR No. 145184 2008-03-14	PRESIDENTIAL AD HOC FACT-FINDING COMMITTEE ON BEHEST LOANS v. ANIANO A. DESIERTO NACHURA, J.
For one to have violated Section 3(e) of R.A. No. 3019, the following elements must be established: 1) the accused must be a public officer discharging administrative, judicial or official functions; 2) he must have acted with manifest partiality, evident bad faith or inexcusable negligence; and 3) he must have caused undue injury to any party, including the government, or given any private party unwarranted benefits, advantage or preference, in the discharge of his functions.[18] Evidently, mere bad faith or partiality and negligence per se are not enough for one to be held liable under the law. It is required that the act constitutive of bad faith or partiality must, in the first place, be evident or manifest, while the negligent deed should be both gross and inexcusable. Further, it is necessary to show that any or all of these modalities resulted in undue injury to a specified party.[19]
	GR NOS. 167006-07 2007-08-14	DANILO D. COLLANTES v. SIMEON MARCELO NACHURA, J.
The elements of the offense are: 1) the accused must be a public officer discharging administrative, judicial or official functions; 2) he must have acted with manifest partiality, evident bad faith or inexcusable negligence; and 3) that his action caused any undue injury to any party, including the government, or gave any private party unwarranted benefits, advantage or preference in the discharge of his functions.[27] Evidently, mere bad faith or partiality and negligence per se are not enough for one to be held liable under the law, since the act constitutive of bad faith or partiality must, in the first place, be evident or manifest, respectively, while the negligent deed should be both gross and inexcusable. It is further required that any or all of these modalities ought to result in undue injury to a specified party.[28]

DEMIE L. URIARTE v. PEOPLE