G.R. No. 125509 - Public Interest Center, Inc. vs. Roxas

Cresenciano Gatchalian and Zenaida Pia, faculty members of the Polytechnic University of the Philippines (PUP), filed a complaint with the Office of the Ombudsman alleging violations of Republic Act No. 3019.
The complaint targeted several PUP administrators involved in questionable transactions amounting to irregular payments and overpayments.
A special audit by the Commission on Audit (COA) resulted in SAO-SOG Report No. 93-19 and led to the docketing of COA Case No. 92-290.
Subsequent to the audit and an attendant memorandum from the COA Review Panel, petitioner Olonan submitted her request for reconsideration of the COA finding.

An Information was filed in the Sandiganbayan criminal cases against the accused, including Dr. Zenaida Olonan (President of PUP), Dr. Dante Guevarra (Vice-President for Administration and Finance), Atty. Augustus F. Cesar (Administrative Officer V), and Mr. Adriano A. Salvador (Acting Chief of the Accounting Office).
The accusatory portion cited a series of questionable transactions, including:

Non-turnover of unused and scrap construction materials following the construction of school buildings.
Overpayments for terminal leave benefits and irregular payments for technical and supervisory services, as well as honoraria to PUP officials.
Overpayments related to land transactions and administrative lapses in formalizing property documentation.
Improper certifications and payments exceeding prescribed fees in transactions related to construction, renovation, and other services.

The Information emphasized that the accused, by virtue of their positions, acted in evident bad faith, manifest partiality, and with a single criminal intent.

The cases were designated under multiple criminal case numbers (e.g., Criminal Case Nos. 23082, 23084–23097), with one case (Criminal Case No. 22854) later withdrawn following a motion filed by the Special Prosecutor on January 8, 1996.
Despite an initial recommendation by a Graft Investigation Officer to dismiss the charges, the Ombudsman adopted a contrary view, following recommendations by Special Prosecution Officers who favored filing 17 Informations against the accused.
A Memorandum from retired Court of Appeals Associate Justice Alfredo Marigomen, acting as a Special Assistant in the Office of the Ombudsman, recommended modifications in the charges—specifically targeting petitioner Olonan’s inclusion in certain cases.
On June 4, 1996, the COA exonerated petitioner Olonan in its decision on SAO-SOG Report No. 93-19, a move that later became part of the record in subsequent proceedings.

Orders by the Graft Court and the Special Prosecutor’s Motion for Reconsideration

On January 26, 1998, the graft court issued an Order dismissing 13 criminal cases (including Criminal Case Nos. 23082, 23084, 23085, 23086, 23087, 23089–23094, 23096, and 23097) against the petitioners based on the Special Prosecutor’s motion anchored on Justice Marigomen’s Report.
The Special Prosecutor later filed a motion for the partial reconsideration on February 20, 1998, contesting the dismissal by asserting that Justice Marigomen’s findings applied only to petitioner Olonan and not to the other accused.
The Special Prosecutor argued that the dismissal of the 13 cases against petitioners Guevarra, Cesar, and Salvador was factually and legally unfounded.

On April 6, 1999, despite the motion for reconsideration being filed three days beyond the prescribed fifteen-day reglementary period, the Sandiganbayan, in its Resolution, reinstated the 13 dismissed cases against the petitioners.
The Resolution was premised on the interest of “substantial justice” and involved a rectification of what was considered a void dismissal based on an erroneous interpretation of Justice Marigomen’s recommendation.
Petitioners contended that the dismissal order had become final and executory due to the lapse of the reglementary period, and that the Sandiganbayan lacked jurisdiction to modify it.

Whether the Sandiganbayan committed grave abuse of discretion in reinstating the 13 criminal cases against the petitioners on the basis of a motion for reconsideration filed by the prosecution beyond the fifteen-day reglementary period.
Whether the Sandiganbayan committed grave abuse of discretion in granting the motion for reconsideration solely on the grounds cited by the prosecution.
Whether an order or resolution that has become final and executory due to the lapse of the reglementary period may be set aside if it is void due to a defect in jurisdiction or an error constituting grave abuse of discretion.
Whether the reliance on Justice Marigomen’s Report—which was intended to recommend only the dropping of petitioner Olonan in certain cases—justifies the dismissal of the 13 criminal cases against the other petitioners.