Case Digest (G.R. No. 242506-10)
Facts:
Luis Ramon P. Lorenzo v. Hon. Sandiganbayan (Sixth Division) and the People of the Philippines, G.R. Nos. 242506-10 and 242590-94, September 14, 2022, Supreme Court Third Division, Caguioa, J., writing for the Court. The petitioners are Luis Ramon P. Lorenzo (former Secretary, Department of Agriculture) and Arthur C. Yap (former Administrator, National Food Authority); respondents are the Sandiganbayan (Sixth Division) and the People of the Philippines (represented by the Office of the Ombudsman / Office of the Special Prosecutor).In 2018 the Ombudsman filed five separate Informations for violation of Section 3(e) of R.A. 3019 against Lorenzo, Yap, and a Philphos representative, arising from the 2003 Luzon-wide procurement of granular urea under the GMA Rice Program. The Informations alleged that Lorenzo authorized negotiated procurement (instead of competitive bidding), and that Yap issued implementing guidelines (simultaneous bid openings at NFA Central, relaxing depot-location eligibility) to secure awards to Manila‑based Philphos, causing undue injury or conferring unwarranted benefits.
The Ombudsman had earlier conducted fact-finding and preliminary investigation proceedings; its July 25, 2017 Joint Resolution found probable cause for Section 3(e) in the Luzon transactions but in other regional cases (Visayas and Mindanao) its resolutions dismissed complaints for lack of probable cause, reasoning that negotiated procurement was justified under E.O. 40 and Section 77 of the IRR‑A to R.A. 9184. Lorenzo and Yap moved to quash the five criminal Informations in the Sandiganbayan on grounds that the alleged facts did not constitute an offense, that the Ombudsman delayed unreasonably (violating the right to speedy disposition), and that evidence aliunde (including prior Ombudsman resolutions) should be considered.
The Sandiganbayan, in Resolutions dated August 9 and September 25, 2018, denied the motions to quash, holding that an information need only allege ultimate facts, that matters of defense and extrinsic evidence are for trial, and that petitioners had waived any speedy‑disposition claim. Lorenzo and Yap filed consolidated...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion in denying the motions to quash by failing to dismiss the Informations for violation of petitioners’ right to speedy disposition of cases?
- Did the Sandiganbayan commit grave abuse of discretion in refusing to consider evidence aliunde (including prior Ombudsman resolutions) in resolving the motions to quash, in light of the exception to...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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