Case Digest (G.R. No. 228904) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 10, 2012, the Office of the Ombudsman filed Criminal Case No. SB-12-CRM-0174 before the Sandiganbayan, First Division, accusing then–President Gloria Macapagal-Arroyo (Arroyo), PCSO Budget and Accounts Officer Benigno B. Aguas (Aguas), and eight (8) other public officers of the crime of plunder under Republic Act No. 7080, as amended by RA 7659. The Information charged that between January 2008 and June 2010, the accused “conniving, conspiring and confederating” diverted at least ₱365,997,915.00 from the PCSO’s Confidential and Intelligence Fund (CIF), purportedly via loans on minimal restrictions, disbursement vouchers and fictitious expenditures, thereby raiding the public treasury and unjustly enriching themselves. Arroyo’s signature “OK” appeared on seven (7) separate requests by PCSO General Manager Rosario C. Uriarte asking for additional CIF allocations, despite PCSO having been in deficit. Aguas, as Budget and Accounts Manager, certified on multiple vouchers that Case Digest (G.R. No. 228904) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On July 10, 2012, the Office of the Ombudsman filed an Information in the Sandiganbayan (SB-12-CRM-0174) charging then‐President Gloria Macapagal-Arroyo (GMA), PCSO Budget and Accounts Officer Benigno B. Aguas, PCSO General Manager Rosario C. Uriarte, PCSO Chair Sergio O. Valencia, PCSO Board members Manuel L. Morato, Jose R. Taruc V, Raymundo T. Roquero, Ma. Fatima A.S. Valdes, COA Chairman Reynaldo A. Villar, and COA Head Nilda B. Plaras with plunder under RA 7080 as amended by RA 7659.
- The Information alleged that from January 2008 to June 2010, the accused, in connivance, diverted and misused PCSO’s Confidential/Intelligence Fund (CIF) totalling PHP365,997,915.00 by:
- diverting operating budget to CIF and converting proceeds to fictitious expenditures;
- raiding the public treasury through irregular disbursement vouchers; and
- taking advantage of official positions to unjustly enrich themselves.
- Proceedings below
- Bail petitions: The SB granted bail to some co-accused but denied GMA and Aguas’ petitions on November 5, 2013, finding strong evidence against them.
- Trial and demurrers: After the prosecution rested, GMA, Aguas, Valencia, Morato, Roquero, Taruc V, and Villar filed demurrers to evidence. On April 6, 2015, the Sandiganbayan denied the demurrers of GMA, Aguas, and Valencia (but granted others’ demurrers). On September 10, 2015, motions for reconsideration by GMA and Aguas were likewise denied.
Issues:
- Procedural Issue
- Whether a special civil action for certiorari is proper to assail the SB’s denial of demurrers to evidence.
- Substantive Issues
- Did the prosecution sufficiently allege and prove conspiracy among GMA, Aguas, and Uriarte?
- Did the prosecution prove all elements of plunder, especially:
- amassing, accumulating or acquiring ill‐gotten wealth of at least PHP50,000,000.00; and
- the predicate act of raiding the public treasury under Section 1(d)(1) of RA 7080?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)