Facts:

The case involves Susana B. Cabahug, the petitioner, against the People of the Philippines, the Sandiganbayan, 3rd Division, and the Office of the Special Prosecutor, the respondents. The events leading to this case began with a negotiated contract entered into by the Department of Education, Culture and Sports (DECS), represented by Cabahug, for the purchase of 46,000 units of Topaz Monobloc Armchairs from Rubber Worth Industries Corporation (RWIC) at a price of P495.00 per unit. This contract was approved by Ricardo T. Gloria, the then Secretary of DECS. However, Jesusa T. de la Cruz, a competing supplier, objected to the contract, claiming that the chairs were overpriced and that the procurement violated Republic Act No. 3019. Following this, a complaint was filed against Cabahug and others before the Office of the Ombudsman-Mindanao, which led to a resolution finding probable cause against Cabahug for violation of Section 3(e) of R.A. No. 3019. An Information was subseque...

Facts:

1. Negotiated Contract for Armchairs:

   • Petitioner Susana Cabahug, as Regional Director of the Department of Education, Culture and Sports (DECS) Region XI, entered into a negotiated contract with Rubber Worth Industries Corporation (RWIC) for the purchase of 46,000 units of Topaz Monobloc Armchairs at P495.00 per unit.
   • The contract was approved by DECS Secretary Ricardo T. Gloria.

2. Objections to the Contract:

   • Jesusa T. de la Cruz, another DECS supplier, objected to the contract, claiming it was overpriced and violated Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
   • Atty. Meliton R. Reyes, representing de la Cruz, alleged the contract was overpriced by P5,000,000.00.

3. Investigation and Recommendations:

   • DECS Undersecretary Antonio E.B. Nachura recommended proceeding with the contract, citing time constraints and the need to utilize the 1995 budget.
   • The Office of the Ombudsman-Mindanao found probable cause against Cabahug for violating Section 3(e) of R.A. 3019, but dismissed charges against Gloria and Nachura.

4. Filing of Information and Motions:

   • An Information was filed against Cabahug before the Sandiganbayan, alleging she caused undue injury to the government and gave unwarranted benefits to RWIC.
   • Cabahug filed motions for reinvestigation and re-determination of probable cause, which were denied by the Sandiganbayan.

5. Divergent Opinions in the Ombudsman’s Office:

   • Special Prosecution Officer Cicero Jurado recommended dismissing the case, finding no bad faith or gross negligence on Cabahug’s part.
   • Ombudsman Aniano Desierto disagreed, insisting on prosecution.

Issue:

1. Whether the Sandiganbayan committed grave abuse of discretion in denying Cabahug’s motion for re-determination of probable cause.
2. Whether there was sufficient evidence to establish probable cause against Cabahug for violating Section 3(e) of R.A. 3019.

Ruling:

The Supreme Court granted the petition and ordered the dismissal of Criminal Case No. 23458. The Court found that:

• The Sandiganbayan committed grave abuse of discretion in denying Cabahug’s motion for re-determination of probable cause.
• There was no sufficient evidence to establish probable cause against Cabahug for violating Section 3(e) of R.A. 3019.

Ratio:

1. Presumption of Good Faith:

   • Good faith is presumed in the performance of official duties. The burden of proving bad faith lies on the accuser. The Ombudsman failed to provide clear evidence of bad faith or gross negligence on Cabahug’s part.

2. Authority to Enter into Negotiated Contracts:

   • Cabahug acted within her authority and followed proper procedures, including consultations with the Commission on Audit (COA) and adherence to directives from her superiors. The negotiated contract was approved by DECS Secretary Gloria and recommended by Undersecretary Nachura.

3. Divergent Opinions in the Ombudsman’s Office:

   • The conflicting findings within the Ombudsman’s office (between the Special Prosecutor and the Ombudsman) highlighted the lack of a clear basis for prosecution. The Court emphasized that the Ombudsman’s discretion must not be exercised arbitrarily.

4. Absence of Probable Cause:

   • The evidence did not support a prima facie case against Cabahug. The Court found no basis to proceed with the trial, as further prosecution would amount to harassment.

5. Judicial Review of Ombudsman’s Actions:

   • While courts generally respect the Ombudsman’s investigatory and prosecutorial powers, they may intervene when there is grave abuse of discretion. In this case, the Sandiganbayan’s refusal to dismiss the case despite the lack of probable cause warranted judicial intervention.

Conclusion:

The Supreme Court ruled that the Sandiganbayan gravely abused its discretion in allowing the prosecution of Cabahug. The Court ordered the dismissal of the case for lack of probable cause, sparing Cabahug from the unnecessary burden of trial.