G.R. No. 129904 - Domondon vs. Sandiganbayan

Petitioner Director Domondon faced several criminal cases filed against him and others before the Sandiganbayan.
Four separate informations were filed in February and May 1994, with cases designated as Crim. Case Nos. 20185, 20191, 20192, and 20576, arising from allegations of irregularities within the Philippine National Police (PNP) during CY 1992.
An additional information, Crim. Case No. 20574, was filed in May 1994 before the First Division of the Sandiganbayan, stemming from a corruption complaint dated May 11, 1993, involving irregular procedures such as irregular issuance of Advices of Sub-Allotments, ghost purchases, forged payrolls, and false issuances of combat equipment valued at P83,600,000.00.

The alleged irregularities linked to the PNP included ghost purchases, irregular allotments, and fraudulent payroll actions.
Petitioner was implicated through his approval, in his capacity as Director of the Office of the Directorate for Comptrollership (ODC), for the release of specific Advices of Allotment (ASAs) amounting to P5 million and P15 million, which were actually executed by his co-accused under his authority.

On May 12, 1994, petitioner filed a motion for consolidation seeking to merge Crim. Case No. 20574 with the other pending cases in the Third Division of the Sandiganbayan.
On May 17, 1994, the First Division issued two orders:

The first directed the prosecution to demonstrate probable complicity of the accused in the violation of the Anti-Graft and Corrupt Practices Act.
The second order deferred action on the motion for consolidation, citing uncertainties regarding the consolidation’s propriety and jurisdictional concerns.

Subsequent proceedings included the cancellation of the scheduled arraignment and issuance of orders by the Office of the Special Prosecutor/Ombudsman, which recommended a modification to the filing by excluding some accused but, notably, continuing the prosecution against the petitioner.
Petitioner later filed a motion for reconsideration (May 17, 1995) addressing both the exclusion and the non-consolidation of affected cases.
On November 29, 1995, an Order was issued recommending the modification of earlier proceedings to exclude petitioner from Crim. Case No. 20574, though this recommendation was eventually disapproved by Ombudsman Desierto on February 19, 1997.

Developments following the issuance of earlier orders saw further procedural adjustments, including the filing of a Motion to Admit Amended Information on August 26, 1997, which restored petitioner as an accused in the revised information.
Petitioner’s subsequent manifestations, including one dated June 30, 1999, claimed that similar factual antecedents justified the consolidation of related cases.
These filings emphasized the perceived overlap in the petitioner’s alleged participation across multiple criminal cases (including Crim. Cases Nos. 20185, 20574, 20191, 20192, 20576, and 22098).

Petitioner alleged that the denial of his motion for reconsideration by Ombudsman Desierto and Overall Deputy Ombudsman Villa constituted grave abuse of discretion amounting to lack or excess of jurisdiction.
He further argued that the denial of his motion for consolidation by respondents Desierto, Villa, and Deputy Special Prosecutor Tamayo was similarly improper, contending that the existing remand of cases to the Office of the Special Prosecutor under the Ombudsman implied that jurisdiction had “revested” in that office.
Petitioner maintained that the evidentiary record did not substantiate probable cause against him and that the decisions were made arbitrarily, disregarding the evidence he adduced.

Whether grave abuse of discretion amounting to lack or excess of jurisdiction occurred when:

Respondents Villa and Desierto denied the petitioner’s motion for reconsideration, despite his claim of insufficient evidence and lack of probable cause.
Respondents Villa, Desierto, and Tamayo denied the petitioner’s motion for consolidation of Crim. Case No. 20574 with the other related cases pending before the Sandiganbayan.

Whether the respondent First Division of the Sandiganbayan should be enjoined from proceeding with the hearing and other incidents in Crim. Case No. 20574 against the petitioner during the pendency of the petition.