G.R. No. 144760-61 - Miranda vs. Sandiganbayan

In August 1990, DECS Region XI Director Venancio R. Nava and his school superintendents met to discuss the issuance of Allotment Advice No. B-2-0392-90-2-014, dated 21 June 1990.
During the meeting, it was agreed that the P9.36 million allotment—intended for nationalized high schools—would be sub‐allotted to divisions for procuring science laboratory tools and devices (SLTDs) without undergoing public bidding, to avoid reversion of funds by the end of the calendar year.

The DECS Division of Davao Oriental executed two separate transactions with D'Implacable Enterprises, owned by Antonio S. Tan, wherein the procurement was conducted through negotiated purchase.
Payment for these procurements was made using allotments originally meant for additional miscellaneous operating expenses for the twenty nationalized high schools of Davao Oriental, with sales representation provided by Evelyn L. Miranda.

On 8 January 1991, the COA Regional Office No. XI, through Assignment Order No. 91-174, constituted an audit team headed by Laura Soriano with Carmencita Eden T. Enriquez as a member.
The audit team was tasked to review the releases made by DECS Region XI involving the P9.36 million allotment, producing a Special Audit Report that alleged overpricing in the transactions, claiming price differentials ranging from 64% to 1,175%—resulting in alleged losses to the government.

Based on the special audit report and a corresponding affidavit of complaint (docketed as OMB-MIN-91-0202), the Office of the Ombudsman-Mindanao filed informations before the Sandiganbayan on 8 April 1997.
Two separate criminal cases were instituted:

Criminal Case No. 23625 (docketing transaction on 16 November 1990) detailing the purchase of items such as test tube glass pyrex, glass spirit burners, spring balances, and bunsen burners, with dramatic disparities between paid prices and canvassed market prices.
Criminal Case No. 23626 (docketing transaction on 27 December 1990) involving purchase of items such as flusk brushes, graduated cylinders, iron wire gauges, and 250 ml. beakers, again highlighting excessive price margins significantly above prevailing market rates.

During trial, the prosecution presented auditor Soriano as a witness, and testimonies were taken from Nava and Obenza. Nava contended that the documents had been prepared by Obenza’s office and asserted that his signature was valid given the monetary threshold and departmental policies.
Other respondents, including Prudencio N. Mabanglo, testified regarding the procedural handling of documents, while Austero, Tan, and Miranda refrained from testifying.

On 10 January 2005, the Sandiganbayan rendered decisions in Criminal Cases Nos. 23625-26, convicting Nava, Obenza, Tan, and Miranda of violating Section 3(g) of R.A. No. 3019 by entering disadvantageous contracts and sentencing them to indeterminate penalties, while acquitting Exuperia B. Austero for insufficiency of evidence.
Subsequent motions for reconsideration filed by Obenza, Miranda, and Nava were denied by the Sandiganbayan on 7 March 2005.

Allegation that the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction by denying her motion to quash the informations.
Claim that the disputed resolution ran contrary to the principle of stare decisis and settled jurisprudence.
Argument that the court should be restraining further proceedings to avoid mootness and academic controversy.

Allegation that the Sandiganbayan committed grave abuse of discretion by relying on findings of a special audit team that conducted an irregular and unauthorized audit.
Claim that the audit team failed to comply with the minimum procedural standards, suppressed evidence favorable to him, and that there was no competent evidence to establish overpricing.
Assertion that his alleged pre-signing of procurement documents lacked documentary proof and that there was no evidence showing a conspiracy warranting his conviction.

Contention that the Sandiganbayan erred in convicting him for violating R.A. No. 3019, including the charge of conspiracy with Nava.
Argument emphasizing that similar cases with like facts had been previously decided in favor of the accused, invoking the doctrine of stare decisis.
Claim that the Sandiganbayan's refusal to review pertinent evidence and its reliance on self-serving testimony led to an erroneous decision on his liability.