Case Digest (G.R. No. 210488) Core Legal Reasoning Model
Facts:
In 2009, the Philippine National Police (PNP) procured one brand-new and two purportedly brand-new Robinson R44 helicopters from Manila Aerospace Products Trading Corporation (MAPTRA) for a total of ₱104,985,000. The Field Investigation Office of the Ombudsman (FIO-OMB) charged petitioner Jose Miguel T. Arroyo, his brother Ignacio, MAPTRA President Hilario De Vera, and certain PNP officers with violating Sections 3(e) and 3(g) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The Ombudsman relied heavily on the affidavit and Senate Blue Ribbon Committee testimony of Archibald Po, owner of Lionair Inc. and Asian Spirit Inc., who claimed Arroyo funded and controlled the two pre-owned helicopters (SN 1372 & 1374) sold to MAPTRA. Arroyo denied any ownership or involvement, presenting FAA export certificates, Air Transportation Office registrations, invoices, deeds of sale, a deed of assignment of his shares in Lourdes T. Arroyo, Inc. (LTA), and tax payment certif
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Case Digest (G.R. No. 210488) Expanded Legal Reasoning Model
Facts:
- Helicopter Procurement
- In 2009, the Philippine National Police (PNP) contracted Manila Aerospace Products Trading Corporation (MAPTRA) to purchase one brand-new Robinson R44 Raven II and two Robinson R44 Raven I helicopters for a total of ₱104,985,000.00.
- National Police Commission rules required all units to be brand-new, but two Raven I helicopters (SN 1372, 1374) were allegedly pre-owned by then-First Gentleman Jose Miguel T. Arroyo (Arroyo).
- Archibald Po’s Affidavit and Senate Statements
- Po, owner of Lionair Inc. and Asian Spirit Inc., testified he purchased five R44 Raven I helicopters upon Arroyo’s request, imported them tax-free under Asian Spirit, and charged maintenance fees to Arroyo.
- Po alleged in June 2009 he sold two pre-owned Raven I helicopters to MAPTRA at US$448,173.73 each, turned them over in December 2009, and remitted proceeds to Arroyo.
- Arroyo’s Denials and Documentary Evidence
- Arroyo filed a counter-affidavit denying involvement, insisting Lourdes T. Arroyo, Inc. (LTA)––run by his brother Iggy––advanced funds to Po, and that he divested from LTA in 2001.
- He submitted export certificates, invoices, and ATO registrations showing Lionair/Aisan Spirit as owners, and a Deed of Assignment (2001) transferring his LTA shares to Benito Araneta.
- Ombudsman Preliminary Investigation
- The Field Investigation Office of the Ombudsman (FIO-OMB) found probable cause to charge Arroyo under Section 3(e), R.A. No. 3019, citing Arroyo’s alleged beneficial ownership and trust relationship with Po, despite deed registration issues.
- Denying Arroyo’s motion for reconsideration (Feb. 15, 2013), the OMB emphasized unregistered share transfer, irrevocable proxy clause, and testimony of a Lionair dispatcher.
- Sandiganbayan Proceedings and Supreme Court Action
- Information SB-12-CRM-0164 was filed; Arroyo posted bail and sought judicial determination of probable cause before Sandiganbayan.
- Sandiganbayan denied his motion (Aug. 15, 2013; Nov. 6, 2013). Arroyo filed a certiorari petition under Rule 65 in the SC, which (Jan. 27, 2020) dismissed it for lack of grave abuse of discretion and mootness after Sandiganbayan’s independent probable-cause finding.
- Arroyo’s subsequent Motion for Reconsideration reiterates lack of evidence, absence of conspiracy, and alleged misappreciation of facts; the OSG opposes.
Issues:
- Did the Sandiganbayan commit grave abuse of discretion in finding probable cause and exercising jurisdiction over Arroyo, a private individual, absent evidence of conspiracy with public officers?
- Was Arroyo’s right to a speedy disposition of his case violated given the protracted proceedings and purported lack of evidence?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)