Case Digest (G.R. No. 214336-37)
Facts:
Quirino M. Libunao v. People of the Philippines, G.R. Nos. 214336-37, February 15, 2022, Supreme Court First Division, Lopez, J., writing for the Court.Petitioner Quirino M. Libunao, a former Regional Director of the Department of the Interior and Local Government (DILG)–Caraga, challenged his conviction for violation of Section 3(e) of Republic Act No. 3019 before the Supreme Court. The respondent is the People of the Philippines; other accused in the underlying proceedings included Representative Constantino H. Navarro, Jr., several DILG officials, and private suppliers implicated in the questioned procurements.
The controversy began with a COA special audit (Assignment Order No. 00-002, Jan. 17, 2000) of Navarro’s Countrywide Development Fund for 1997–1998, which found P13,832,569 used for assorted purchases (medicines, drug-testing kits, nebulizers, araro plows, school supplies, etc.) procured by direct contracting rather than public bidding in violation of E.O. No. 302. COA issued Notices of Disallowance (Jan. 23, 2001), quantifying alleged overpricing of P2,863,689.36.
The Office of the Ombudsman filed Informations before the Sandiganbayan (Criminal Case Nos. 27796–27805). The Informations alleged that Navarro, Libunao and others, acting with evident bad faith, manifest partiality or gross inexcusable negligence, gave unwarranted benefits to specified suppliers by entering into contracts without public bidding. Libunao pleaded not guilty; the prosecution presented COA auditors and other witnesses and offered documentary evidence (RIVs, POs, DVs, certificates, checks).
On January 16, 2014, the Sandiganbayan, First Division convicted Libunao in Criminal Case Nos. 27803 and 27805 for two counts of violating Section 3(e) of R.A. No. 3019, sentencing him to indeterminate imprisonment (6 years, 1 month to 10 years) with perpetual disqualification from public office, and acquitted several private suppliers for lack of proof. The Sandiganbayan found no public bidding, pre-selection of suppliers, and that Libunao certified and signed documents that consummated the disbursements. His motion for reconsideration was denied on September 12, 2014.
Libunao filed a Consolidated Petition for Review on Certiorari under Rule 45 (filed Oct. 9, 2014) urging (among others) that he was convicted of a crime different from that charged (the Informations purportedly cited Section 3(g)), tha...(Subscriber-Only)
Issues:
- Did petitioner’s conviction under Section 3(e) of R.A. No. 3019 violate his constitutional right to due process because the Informations were captioned as charging Section 3(g) and/or were duplicitous?
- Did the prosecution prove beyond reasonable doubt the elements of a violation of Section 3(e) of R.A. No. 3019 as to petitioner in Criminal Case Nos. 27803 and 27805?
- Can petitioner be exculpated under the Arias doctrine by showing reasonable reliance on subordinates for ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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