G.R. No. 246451 - Leonardo vs. People

On February 11, 2010, the Sangguniang Bayan of Quezon, Bukidnon issued Resolution No. 10th SB 2010-27 authorizing Municipal Mayor Stewart G. Leonardo to procure trucks and heavy equipment for the Municipality of Quezon.
In May 2010, Quezon, through Mayor Leonardo, joined a public auction by United Auctioneers, Inc. (UAI) in Subic, Olongapo City, and paid a bid deposit of ₱100,000.

Mayor Leonardo personally bid for five (5) trucks totaling ₱6,387,500 on behalf of Quezon and separately bid for two (2) pieces of equipment (a hydraulic excavator and a front cut unit cabin) totaling ₱1,670,000 for his private account, using the same ₱100,000 deposit.
UAI declared Quezon the winning bidder for all seven (7) items, issued one statement of account, and two receipts (₱6,387,500 and ₱1,570,000, both in Quezon’s name). The ₱100,000 deposit was deducted from Leonardo’s personal purchase, reducing its balance from ₱1,670,000 to ₱1,570,000. All seven deeds of sale listed “LGU Quezon” as vendee, and all equipment were transported together.

On January 14, 2011, Gregorio L. Gue and Noel Goopio filed a complaint with the Office of the Ombudsman (OMB) alleging violation of Section 3(e), RA 3019. A counter-affidavit was filed May 30, 2011. By Resolution dated January 15, 2015, and subsequent denial of reconsideration on June 15, 2015, probable cause was found.
On June 1, 2016, the OMB filed an Information before the Sandiganbayan charging Leonardo with violation of Section 3(e), RA 3019, for misappropriating Quezon’s bid deposit for his private purchase and directing municipal transport resources to move his equipment.

Leonardo pleaded not guilty; he claimed to have reimbursed Quezon ₱70,000 on October 8, 2010 and ₱30,000 on October 18, 2010, and to have paid ₱1,570,000 for his equipment. He asserted lack of bad faith and absence of prejudice.
By Decision dated November 23, 2018, the Sandiganbayan Fourth Division found him guilty beyond reasonable doubt of violating Section 3(e), RA 3019, sentenced him to an indeterminate penalty of six years and one month to ten years’ imprisonment with perpetual disqualification from public office, and ordered reimbursement of ₱8,134.80 for transport costs. A Resolution dated March 1, 2019 denied his motion for reconsideration.

Whether the Sandiganbayan correctly found that Leonardo, as a public officer, acted with manifest partiality and evident bad faith, causing undue injury to Quezon or securing unwarranted benefits for himself.

Whether Leonardo’s reimbursement of the bid deposit and transport costs nullified or mitigated the offense or prejudice to Quezon.
Whether any inordinate delay in the Ombudsman’s preliminary investigation violated Leonardo’s right to speedy disposition of the case.