Case Digest (G.R. No. 126995)
Facts:
Imelda R. Marcos v. The Honorable Sandiganbayan (First Division), and the People of the Philippines, G.R. No. 126995, October 06, 1998, the Supreme Court En Banc, Purisima, J., writing for the Court.Petitioner Imelda R. Marcos was indicted (Criminal Case No. 17450 before the Sandiganbayan) together with Jose P. Dans, Jr. for violation of Section 3(g) of Republic Act No. 3019 (the Anti‑Graft and Corrupt Practices Act). The Information alleged that on June 8, 1984 the accused, as then Chairman and Vice‑Chairman of the Light Rail Transit Authority (LRTA), conspired to enter into a Lease Agreement (Exhibit “B”) between LRTA and the Philippine General Hospital Foundation, Inc. (PGHFI) that was manifestly and grossly disadvantageous to the government; the PGHFI then executed a Sub‑lease Agreement (Exhibit “D”) with Transnational Construction Corporation (TNCC) for a much higher rental.
The Sandiganbayan (First Division) convicted both Marcos and Dans. Because the original three‑justice First Division failed to reach unanimity, Presiding Justice Garchitorena constituted a Special Division of five under Administrative Order No. 288‑93; later he dissolved it by Administrative Order No. 293‑93 after an informal meeting among some justices, and the First Division promulgated its decision on September 24, 1993. Dans was later acquitted by this Court; Marcos’s conviction was affirmed by the Third Division of the Supreme Court (G.R. No. 126995) on January 29, 1998 (while related dispositions affecting Dans appear under G.R. No. 127073).
Petitioner filed a Motion for Reconsideration in the Supreme Court, raising (inter alia) that: (a) she did not enter into Exhibit “B” on behalf of LRTA because she had signed as PGHFI Chair and there was no evidence she acted as a public officer in executing that contract; (b) the prosecution failed to prove the Lease was manifestly and grossly disadvantageous beyond reasonable doubt (the case rested largely on comparing the P102,760 monthly rental in Exhibit “B” with the P734,000 monthly rent in Exhibit “D”); and (c) procedural irregularities in the Sandiganbayan (creation/dissolution of the Special Division, informal deliberations excluding members) depri...(Pro-only)
Issues:
- Was petitioner deprived of procedural and substantive due process by the Sandiganbayan's handling (creation/dissolution of the Special Division and informal deliberations)?
- Did the prosecution prove beyond reasonable doubt the elements of Sec. 3(g), RA 3019 — namely that petitioner, as a public officer, entered into the Lease on behalf of the government, and that the Lease was manifestly and grossly disadvantageous to the government?
- If defects existed, should the case be remanded to the Sandiganbayan for re‑deci...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)