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:

Procedural Background

• Susana B. Cabahug, the petitioner and then Regional Director of the Department of Education, Culture and Sports (DECS) for Region XI, initiated a petition for Certiorari and/or Prohibition with a Preliminary Injunction and/or Temporary Restraining Order.
• The petition assailed two orders issued by the Sandiganbayan in Criminal Case No. 23458, which arose from motions she filed regarding the existence of probable cause against her.
• The first motion— a Motion for Re-determination of Existence of Probable Cause—was treated as a second motion for reconsideration and, because such successive motions are not allowed, was denied.
• A subsequent Very Urgent Motion for Reconsideration was also denied in open court.

The Negotiated Contract and Procurement Dispute

• A negotiated contract was entered into by DECS, represented by petitioner Cabahug in her capacity as Regional Director, with Rubber Worth Industries Corporation (RWIC) for the purchase of 46,000 units of Topaz Monobloc Armchairs at a unit price of P495.00.
• The price was inclusive of transportation, handling, insurance, and delivery.
• The negotiated contract had been approved by then-Secretary Ricardo T. Gloria of DECS.
• Before the execution of the contract, an objection was raised by another DECS supplier, Jesusa T. de la Cruz, who through her lawyer questioned the pricing and alleged that the transaction was prejudicial to the government and in violation of Republic Act No. 3019.
• On January 2, 1996, Atty. Meliton R. Reyes, counsel for de la Cruz, asserted that the contract was overpriced by P5,000,000.00—a claim that precipitated a formal complaint against petitioner Cabahug and several other officials.

Administrative and Investigative Proceedings

• In response to the complaint:
• The Office of the Ombudsman-Mindanao received the complaint and initiated an investigation.
• Counter-affidavits were submitted by DECS officials, including Secretary Gloria and Undersecretary Antonio E. B. Nachura, contending that the contract was executed after proper consultation with the chairman of the Commission on Audit (COA) and that the procedure observed the existing guidelines.
• Memoranda and other documentary evidence showed:
• The procurement was conducted pursuant to established DECS directives and administrative orders.
• The negotiated contract was recommended after careful consideration, including consultations with COA and various DECS divisions, to maximize savings and ensure timely execution of the government project.
• The investigation by Special Prosecution Officer Cicero D. Jurado, Jr. concluded:
• There was insufficient evidence to find that Cabahug acted with bad faith or gross negligence.
• Her actions were in line with instructions from her superiors.

Subsequent Motions and the Filing of the Criminal Case

• Despite the internal findings and recommendations to dismiss the case on the ground of absent malicious intent, a criminal case was filed against petitioner Cabahug for allegedly causing undue injury to the government under Section 3(e) of R.A. No. 3019.
• Petitioner Cabahug contended that:
• The pending charges were a result of a vindictive complaint by a disgruntled supplier, de la Cruz, who intended to discredit her administration and harass the government.
• She had acted in good faith and followed proper administrative procedures as directed by her superiors.
• The Sandiganbayan, even after granting her Motion for Reinvestigation, ultimately denied her motions for re-determination of probable cause and reconsideration, prompting her to file the present petition for review on the ground of grave abuse of discretion.

Issue:

• Whether the Sandiganbayan committed grave abuse of discretion by denying petitioner Cabahug’s motions for re-determination of the existence of probable cause and reconsideration.
• Whether there existed sufficient evidence to establish a prima facie case against petitioner Cabahug for violating Section 3(e) of R.A. No. 3019, particularly in light of the absence of evidence showing bad faith or gross negligence on her part.
• Whether the court may review and intervene in the prosecutorial and investigatory functions of the Office of the Ombudsman when there is a manifest abuse of discretion that violates the petitioner’s due process rights.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)