CASE ANALYSIS

G.R. No. 220598

GLORIA MACAPAGAL ARROYO, Petitioner
vs.
PEOPLE OF THE PHILIPPINES AND THE SANDIGANBAYAN, (First
Division), Respondents

Read the entire decision of the Supreme Court and answer the following questions:

a) What is the issue of the case that is related to an ambiguity of a law?

Whether or not the accused committing predicate crime of raid on the public
treasury.

b) In five sentences, summarize the relevant facts of the case.

On July 19, 2016, the Court promulgated its decision in favor of the petitioner.
On August 3, 2016 the State has moved for the consideration of the decision.
GMA barred the granting of the motion for reconsideration of the State because
doing so would amount to the revival of the charge against them despite their
acquittal. Benigno B. Aguas echoes to deny the motion for reconsideration.

c) In three sentences, give the ruling of the Supreme Court. (Begin by

directly addressing the issue)

Prosecution fail to show that GMA and Aguas had personally benefited from the
same. Therefore, the Prosecution did not prove the predicate act of raids on the
public treasury beyond reasonable doubt. The contention lacks basis.

d) How did the Court come up with its resolution of the issue?
(Summarize the reasoning of the court.  Include the principles that we
are currently discussing.  Exclude advance topics in statutory
construction.)

The phrase raids on the public treasury as used in Section 1 (d) of R. A. No.

7080 is itself ambiguous. The maxim of statutory construction noscitur a
sociis,  by which the correct construction of a particular word or phrase that is
ambiguous in itself or is equally susceptible of various meanings may be made
by considering the company of the words in which the word or phrase is found
or with which it is associated. The accompanying words of raids on the public
treasury: misappropriation, conversion, misuse or malversation of public funds.
The common thread that binds all the four terms together is that the public
officer used the property taken. Pursuant to the maxim of noscitur a sociis, raids
on the public treasury requires the raider to use the property taken impliedly for
his personal benefit.