Case Digest (G.R. No. 244076)
Facts:
In Martel v. People (G.R. Nos. 224720-23 and 224765-68, February 2, 2021), petitioners Richard T. Martel, Allan C. Putong, Abel A. Guiaares, Victoria G. Mier, Edgar C. Gan, and Benjamin P. Bautista, Jr. were members of the Provincial Bids and Awards Committee of Davao del Sur in 2003. As Governor, Bautista signed three Purchase Requests for the direct acquisition of five pick-up vehicles—two Toyota Hilux 4x4 SR5, one Mitsubishi L300 Exceed DX2500 Diesel, and two Ford Ranger XLT 4x4—without public bidding. Each Purchase Order and Abstract of Canvass bore a “DIRECT PURCHASE” stamp and specific brand names. After delivery and inspection, disbursement vouchers were signed by Martel and Guiaares. In September 2003, the Concerned Citizens for Good Governance filed a complaint with the Ombudsman alleging irregularities under Section 3(e) of R.A. 3019. The Ombudsman found probable cause, and in October 2012, Informations were filed before the Sandiganbayan. On February 24, 2016, the San...Case Digest (G.R. No. 244076)
Facts:
- Parties, Charges, and Procedural Posture
- Petitioners Richard T. Martel, Allan C. Putong, Abel A. Guiaares, Victoria G. Mier, Edgar C. Gan (all BAC members of Davao del Sur) and Governor Benjamin P. Bautista, Jr. challenged Sandiganbayan’s February 24, 2016 Decision and May 13, 2016 Resolution convicting them under Section 3(e) of R.A. 3019 for “manifest partiality,” “evident bad faith,” or “gross inexcusable negligence” in vehicle procurement.
- They were sentenced to an indeterminate term of 6 years 1 month to 8 years each, perpetual disqualification from public office; Gan’s criminal liability was later dismissed due to his death.
- Procurement of Service Vehicles
- Purchase Requests dated January 24, February 18, and July 15, 2003 (signed by Bautista) requisitioned two units Toyota Hilux 4×4 SR5, one Mitsubishi L300 Exceed DX2500 Diesel, and two Ford Ranger XLT 4×4 for the Governor and Vice Governor.
- The Province’s BAC (composed of the five other petitioners plus Bautista) did not conduct public bidding but approved direct purchases from the declared “exclusive” dealers—Toyota Davao City, Inc.; Kar Asia, Inc.; and Ford Davao—citing LGC Sec. 371. Disbursement vouchers were signed by Martel (Provincial Accountant) and Guiaares (Provincial Treasurer).
- The COA’s special audit (2005) found these transactions “anomalous” and violative of procurement laws. Concerned Citizens for Good Governance lodged a complaint with the Ombudsman, which filed Informations before Sandiganbayan in 2012. Trial ensued (2013–2014); two COA witnesses testified; defense stressed good faith reliance on Sec. 371 and absence of COA disallowance.
Issues:
- Substantive Issue under R.A. 3019, Sec. 3(e)
- Did petitioners act with the requisite criminal state of mind—manifest partiality, evident bad faith, or gross inexcusable negligence—in violating procurement laws?
- Did their acts cause undue injury to any party or confer unwarranted benefits, advantage, or preference?
- Procedural/Factual Review
- Were the Sandiganbayan’s factual findings based on speculation, misapprehension, or insufficient evidence?
- May the Supreme Court review these findings under Rule 45 exceptions (e.g., when findings rest on conjectures, misapprehension of facts, or absence of evidence)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)