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Miguel v. Sandiganbayan
675 SCRA 560
Vice Mayor Lucido and other officials were charged with violation of RA 3019. The Information filed against them states the following wordings: and as such while in the performance of his official functions, committing the offense in relation to his office, taking advantage of his official position, conspiring and confederating with the private [individuals] xxx acting with evident bad faith and manifest partiality, did then and there willfully, unlawfully and criminally give unwarranted benefits and advantages. The petitioner contends that the Informaiton is invalid. He alleges that the phrases "evident bad faith" and "manifest partiality" actually refers not to him, but to his co-accused, rendering the information fatally defective.
Whether or not the Information is valid
Yes, the Information is valid. The Supreme Court ruled that the phrase "acting with evident bad faith and manifest partiality" was merely a continuation of the prior allegation of the acts of the petitioner, and that he ultimately acted with evident bad faith and manifest partiality in giving unwarranted benefits and advantages to his co-accused private individuals. This is what a plain and non-legalistic reading of the information would yield. The petitioner actually disputes is simply the clarity of the phrase’s position, in relation with the other averments in the information. Given the supposed ambiguity of the subject being qualified by the phrase "acting with evident bad faith and manifest partiality," the remedy of the petitioner, if at all, is merely to move for a bill of particulars and not for the quashal of an information which sufficiently alleges the elements of the offense charged