G.R. No. 216838-39 - Janet Lim Napoles vs. Hon. Conchita Carpio Morales, People, and Sandiganbayan

Petitioners Janet Lim Napoles, John Raymund De Asis, and Alan A. Javellana were charged by the Office of the Ombudsman (OMB) based on complaints filed by the National Bureau of Investigation (NBI) and the OMB-Field Investigation Office.
The complaints concerned the Priority Development Assistance Fund (PDAF) scam involving the misuse and siphoning of public funds allocated to Masbate 3rd District Representative Rizalina L. Seachon-Lanete for the years 2007-2009 totaling PHP 112,290,000.00.

NBI and Atty. Levito Baligod (private counsel for whistleblower Benhur Luy and others) filed a complaint against Representative Seachon-Lanete, Napoles, Javellana, and others for plunder (OMB-C-C-13-0320).
OMB-Field Investigation Office lodged a similar complaint against Napoles, De Asis, Javellana, and others, charging plunder and violation of Section 3(e) of Republic Act (RA) No. 3019 (OMB-C-C-14-0017).
Whistleblowers included employees of the JLN Corporation: Luy, Marina Sula, and Merlina SuAas.

Napoles negotiated with Representative Seachon-Lanete for the use of her PDAF allocation in exchange for kickbacks (commission), with the lawmaker's share pegged at 60%.
Napoles advanced kickback payments using her funds to start the scheme.
Several JLN-controlled dummy NGOs served as conduits for the funds.
Spurious receipts and liquidation documents were used to simulate legitimate project implementation.
De Asis acted as driver/messenger/janitor and was a board member/incorporator in one of the NGOs (CARED).
Javellana, former Director and President of NABCOR, signed memorandums of agreement and disbursement documents related to the PDAF projects.

Representative Seachon-Lanete endorsed funding to JLN-controlled NGOs without public bidding.
PHP 112,290,000.00 of PDAF funds were requested and released to various agencies and then endorsed to the NGOs.
The PDAF funds were ultimately misappropriated.
Napoles, De Asis, and Javellana submitted counter-affidavits denying or contesting allegations, questioning evidence and witnesses.

On September 26, 2014, the OMB issued a Joint Resolution finding probable cause to indict the petitioners for plunder and violations of Section 3(e) of RA No. 3019.
The Joint Resolution detailed the conspiracy, the scheme involving various government officials, and the substantial ill-gotten wealth amassed.
The OMB denied motions for reconsideration filed by the petitioners in a Joint Order dated November 26, 2014.

Napoles contended that the complaints were insufficient in form and substance, lacked credible evidence, and that she was not a public officer.
De Asis argued no evidence showed his criminal intent or knowledge, and that he was merely performing duties as driver/messenger/janitor.
Javellana invoked the Arias doctrine to claim good faith reliance on subordinates’ recommendations and denied knowledge of irregularities.

Whether the Office of the Ombudsman gravely abused its discretion in finding probable cause to indict the petitioners for plunder and/or violations of Section 3(e) of RA No. 3019.
Whether the complaints and filed informations were sufficient in form and substance.
Whether the petitioners, particularly Napoles and De Asis as private individuals, can be held liable as co-conspirators with public officers.
Whether the testimonies of whistleblowers and use of hearsay evidence during preliminary investigation were admissible.
Whether the Arias doctrine applies to Javellana’s case, absolving him of liability.