G.R. No. 212761-62 - Estrada vs. Office of the Ombudsman

Senator Jinggoy Ejercito Estrada – accused of diverting his Priority Development Assistance Fund (PDAF) allocations (2004–2012) for personal “commissions.”
John Raymund de Asis – Napoles’ driver/messenger and incorporator/president of a Napoles-controlled NGO (Kaupdanan Para sa Mangunguma Foundation, Inc.).
Janet Lim Napoles – alleged mastermind of the PDAF scam, organizer of “conduit” NGOs.

Office of the Ombudsman (Ombudsman) – conducted the preliminary investigations.
Sandiganbayan – court where Informations were filed after Ombudsman’s resolutions.
National Bureau of Investigation (NBI) and Ombudsman Field Investigation Office (FIO) – complainants.

NBI Complaint (OMB-C-C-13-0313; 16 Sep 2013) – charged Estrada, De Asis, Napoles, and others with Plunder under Republic Act No. 7080 for awarding Estrada’s PDAF to ghost NGOs in exchange for kickbacks totaling at least ₱183.79 million.
FIO Complaint (OMB-C-C-13-0397; 18 Nov 2013) – charged same respondents with Plunder and 11 counts of violation of Sec. 3(e) of RA 3019 for manifest partiality and bad faith in diverting more than ₱278 million of Estrada’s PDAF.
Modus Operandi

Napoles negotiated a “commission” (40–60%) with legislators in exchange for listing projects and down payments.
Legislators’ offices endorsed ghost NGOs (controlled by Napoles) to the DBM and implementing agencies (IAs).
Upon SARO/NCA releases, Napoles’ staff prepared fictitious liquidation documents; checks were deposited in NGOs’ accounts.
De Asis and other cohorts delivered kickbacks to the legislators’ representatives.

Ombudsman Orders (Nov 2013) – petitioners ordered to submit counter-affidavits; Estrada complied, De Asis and Napoles partly defaulted. Co-respondents filed theirs.
Request for Co-respondents’ Affidavits – Estrada sought copies of Tuason, Cunanan, Amata, Relampagos affidavits; initially denied (Ombudsman Mar 27 2014), later subject of separate SC petition.
Ombudsman Resolutions

Joint Resolution (Mar 28 2014) – found probable cause to indict Estrada, De Asis, Napoles, and others for Plunder and 11 counts of Sec. 3(e), RA 3019.
Joint Order (Jun 4 2014) – denied motions for reconsideration.

Informations Filed (Jun 2014) – Ombudsman lodged Informations in Sandiganbayan charging Plunder and violation of Sec. 3(e).

Did the Ombudsman gravely abuse its discretion by refusing to furnish Estrada with copies of co-respondents’ affidavits, violating his right to due process?
Did the Ombudsman gravely abuse its discretion (lack/excess of jurisdiction) in finding probable cause against Estrada, De Asis, and Napoles for Plunder (RA 7080) and 11 counts of Sec. 3(e), RA 3019?