Case Digest (G.R. No. 220598)
Facts:
Gloria Macapagal-Arroyo, G.R. No. 220598, and Benigno B. Aguas, G.R. No. 220953, July 19, 2016, the Supreme Court En Banc, Bersamin, J., writing for the Court. The petitions were consolidated and seek certiorari to annul the Sandiganbayan (First Division) resolutions of April 6, 2015 and September 10, 2015 that denied petitioners’ demurrers to evidence and motions for reconsideration.The Office of the Ombudsman filed Information for plunder (Crim. Case No. SB-12-CRM-0174) charging GMA, Aguas, PCSO officials (including Rosario C. Uriarte and Sergio O. Valencia), certain PCSO board members, and COA officials with having amassed or diverted PCSO Confidential/Intelligence Fund (CIF) moneys totaling about P365,997,915. The Sandiganbayan acquired personal jurisdiction over most accused at different times; Uriarte and Valencia remained at large at points. Several accused sought bail; the Sandiganbayan granted bail to some (Valencia, Morato, Roquero, Taruc, Villar) but denied bail to GMA and Aguas in November 2013, finding the evidence of guilt strong.
At trial the State’s primary witness was PCSO audit committee member Atty. Aleta Tolentino, whose detailed testimony and documentary exhibits traced extensive CIF cash advances (2008–2010), irregular designations of special disbursing officers, lack of required fidelity bonds and liquidation papers, commingling of PCSO funds, and COA credit notices with questionable form and timing. The Ombudsman argued that the approvals (many bearing GMA’s “OK” marginal notation), Aguas’ certifications on disbursement vouchers, Uriarte’s encashments and lack of supporting documents evidenced a scheme to raid PCSO coffers.
After the prosecution rested, GMA, Aguas and other accused filed demurrers to evidence. On April 6, 2015 the Sandiganbayan granted the demurrers of some board members and Villar but denied the demurrers of GMA, Aguas and Valencia (finding sufficient evidence of conspiracy and, as to Valencia, malversation), and later ...(Pro-only)
Issues:
- Procedural: Is a petition for certiorari a proper remedy to assail the Sandiganbayan’s denial of demurrer to evidence?
- Substantive (conspiracy): Did the prosecution sufficiently allege and prove a conspiracy among GMA, Aguas, and Uriarte?
- Substantive (plunder elements): Did the prosecution establish the elements of plunder under R.A. No. 7080 — specifically (a) that the accused amassed, accumulated or acquired ill‑gotten wealth of at least P50,000,000, and (b) that the predicate a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)