Facts:

The case presented is a petition for certiorari involving multiple petitioners: Fidel C. Amarillo, Sanchito C. Cabana, Andres M. Marmol, Alexander G. Suril, Rogelio R. Guerrero, Jesus L. Capiendo, Arturo P. Ruzol, Loreto G. Suril, and Carolina D. Querijero, against the Sandiganbayan and the People of the Philippines. The events began on March 21, 1997, when the Fact-Finding and Intelligence Bureau, through its director, filed a complaint-affidavit against the petitioners, officials of the Department of Public Works and Highways in the Aurora Engineering District, and Querijero, a private contractor. The complaint alleged estafa through falsification of public documents tied to repairs claimed to have been made to the Pugo and Dyos bridges, which were reported to have been damaged by flash floods on November 3, 1995.

The investigation, led by Graft Investigation Officer (GIO) Melinda S. Diaz, found sufficient grounds to proceed. Petitioners, instead of submitting counter-affidav

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Facts:

Initiation of the Complaint and Preliminary Investigation

• On March 21, 1997, the Fact-Finding and Intelligence Bureau, through its director, filed a complaint-affidavit with the Evaluation and Preliminary Investigation Bureau (EPIB) of the Office of the Ombudsman.
• Petitioners—Fidel C. Amarillo, Sanchito C. Cabana, Andres M. Marmol, Alexander G. Suril, Rogelio R. Guerrero, Jesus L. Capiendo, Arturo P. Ruzol, and Loreto G. Suril (all officials of the DPWH Aurora Engineering District), along with private contractor Carolina Querijero—were accused of estafa through falsification of public documents.
• The complaint alleged that petitioners simulated a contract with Querijero for the repair of the Pugo and Dyos bridges, claimed to have been damaged following flashfloods originally alleged to have occurred on November 3, 1995.
• The EPIB found sufficient basis to conduct a preliminary investigation and ordered petitioners to submit their counter-affidavits.

Petitioners’ Response and the Investigative Process

• Instead of a proper counter-affidavit, petitioners submitted a letter dated May 20, 1997, stating they were adopting Amarillo’s affidavit from an administrative complaint related to the same subject matter.
• Graft Investigation Officer (GIO) Bienvenida A. Gruta was assigned to the case and gathered evidence and affidavits from multiple witnesses, including:
• Zosimo C. Danay, Jr. (Barangay Chairperson of Barangay Tinib, Casiguran, Aurora)
• Rolando L. Eresmas (Kagawad of Barangay Tinib, Casiguran, Aurora)
• Certification by Geraldine B. Santos, social welfare officer of Barangay Tinib
• Memorandum of Helideliza R. Vicente, Municipal Agriculturist of Casiguran
• The affidavits presented discrepancies regarding the timing, nature of the repairs, and the occurrence of the flashflood, notably differing on whether repairs were undertaken by the Industrial Development Corporation (IDC) or by Caroline Construction.

Submission of Additional Counter-Affidavits and Evidence

• Petitioner Carolina D. Querijero submitted her counter-affidavit with attached documents:
• A photocopy of a letter dated January 4, 1996, from Mayor Fidel Salamera requesting the use of IDC’s crane and boom for bridge repairs.
• A letter from Wilbur Dee, general manager of IDC, granting the said request.
• Mayor Salamera was subsequently included among the respondents after the investigation recommended his inclusion. His counter-affidavit contested the allegations and asserted that:
• Heavy rains on November 3, 1995, caused widespread damage, including to the bridges.
• The repair was undertaken by Caroline Construction, as per the awarded contract by the DPWH Aurora Engineering District.
• The statements of Barangay officials were politically motivated and inaccurate.

Development of Criminal Charges and Subsequent Motions

• On June 23, 1999, GIO Gruta issued a resolution holding sufficient ground for trial on two counts of estafa through falsification of official documents, based on the finding of a conspiracy to misrepresent the repair of the bridges.
• An Information was subsequently filed with the Sandiganbayan in Criminal Case No. 25518, charging the petitioners.
• On September 17, 1999, petitioners filed a motion for reconsideration with the Office of the Special Prosecutor, arguing that they were not afforded an opportunity to answer the affidavits of Danay and Eresmas.
• The Office of the Special Prosecutor recommended denying the motion for reconsideration, citing absence of new evidence and procedural defects; it further recommended amending the Information for greater specificity and completeness.
• On February 17, 2000, an additional Information (Criminal Case No. 25813) was filed and the initial information was amended accordingly.

Filing of the Second Motion for Reinvestigation and Its Denial

• On July 4, 2000, petitioners filed a second motion for leave of court to present a motion for reinvestigation based on allegedly newly discovered evidence.
• The newly introduced evidence consisted of an affidavit by Mineo F. Taduyo, administrative officer of IDC, stating:
• Mayor Salamera requested IDC in writing to permit the use of its heavy equipment for the repair of the bridges.
• Wilbur Dee granted such request.
• On August 16, 2000, the Sandiganbayan denied the second motion for reinvestigation on the ground that Republic Act No. 6770 prohibited a second motion for reinvestigation under the rules governing motions for reconsideration.
• A subsequent motion for reconsideration of this denial was also filed by petitioners, but it was denied in open court on September 27, 2000.

Allegations of Grave Abuse of Discretion and Due Process Violations

• Petitioners contended that by denying their motion for reinvestigation and the motion for reconsideration, the Sandiganbayan committed grave abuse of discretion, thereby violating their right to due process.
• They argued that:
• They were deprived of the opportunity to refute the statements of Danay and Eresmas concerning the alleged non-repair of the bridges by Caroline Construction.
• The denial of the second motion for reinvestigation, despite the alleged presentation of newly discovered evidence, undermined justice.
• Public respondent (Sandiganbayan), through the Office of the Special Prosecutor, maintained that:
• The denial was proper under the existing procedural rules and the Office of the Ombudsman’s Rules of Procedure.
• The evidence presented by Taduyo did not meet the requisites for newly discovered evidence, as it was available during previous investigations and lacked the materiality required to change the findings.

Final Determination in the Case

• The court evaluated whether the denial of the second motion for reinvestigation constituted grave abuse of discretion and a due process violation.
• It held that petitioners had been afforded ample opportunity to explain and rebut the allegations during the preliminary investigation and the subsequent motion for reconsideration.
• The court further determined that Taduyo’s affidavit failed to qualify as newly discovered evidence, as it:
• Was not produced with reasonable diligence after the trial.
• Lacked materiality and the potential to alter the findings of the Office of the Special Prosecutor.
• Consequently, the petition for certiorari was dismissed and the challenged orders of the Sandiganbayan were affirmed.

Issue:

Whether the denial of the second motion for leave of court to file a motion for reinvestigation by the Sandiganbayan constituted grave abuse of discretion.

• Did the court’s refusal violate the petitioners’ right to due process by not affording them an adequate opportunity to be heard?
• Were the procedural rules on motions for reinvestigation applied correctly, thus preventing a third determination on the existence of probable cause?

Whether the affidavit of Mineo F. Taduyo qualifies as newly discovered evidence capable of justifying a reinvestigation.

• Does Taduyo’s affidavit meet the requisites of being discovered after the investigation, not producible with reasonable diligence during the investigation, and of material significance?
• To what extent did the affidavit alter or have the capacity to change the findings of the Office of the Special Prosecutor regarding the existence of probable cause?

• Whether petitioners were denied a fair opportunity to refute evidence presented against them, specifically the statements of Barangay officials Danay and Eresmas and the finding of conspiracy.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)