G.R. No. 205623 - Sonley vs. Anchor Savings Bank

The People of the Philippines filed a petition for review on certiorari under Rule 45 seeking reversal of the Sandiganbayan’s acquittal of three former high-ranking police officials—Cesar P. Nazareno, Everlino P. Nartatez, and Nicasio Ma. Custodio—charged with violating Section 3(g) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act).
The criminal charge arose from three separate but related contracts executed between the Philippine National Police (PNP) and Beltra Industries for the procurement of 5,681 caliber .45 pistols.

PO No. 081190-654 dated November 8, 1990 – Purchase of 2,822 units at P18,550.30 each, totaling P52,348,946.60.
PO No. 0-240-492-185 dated April 24, 1992 – Purchase of 1,617 units for P29,995,835.10.
PO No. 0-050-582-153 dated May 5, 1992 – Purchase of 1,242 units for P23,039,472.60.

The documents were signed by the respondents in their official capacities (the purchase orders by then Director Generals Nazareno and Nartatez, and the corresponding checks by then Director Custodio).

Allegations focused on the significant price difference between the PNP’s purchase price and the lower unit price obtained by the AFP Logistics Command (LOGCOM) under the Foreign Military Sales (FMS) program.

The AFP's unit price was documented at P10,578.25 versus the PNP’s P18,550.30, suggesting the transactions were overpriced by an aggregate amount nearing P45 million.

A tri-agency investigation (PNP Inspector General’s Office, National Police Commission, and the Office of the President) that found no overpricing or collusion.
A special audit team from the Commission on Audit (COA) that determined an apparent overpricing based solely on comparing the AFP price with the PNP price.

Evidence presented at trial included the testimony of members of the special audit team and documentary evidence relating to both the contracts and the alleged price difference.
The respondents defended the transactions by asserting that the AFP’s procurement under the FMS program was inherently different from a local commercial purchase, noting the ineligibility of the PNP for FMS benefits.
The Sandiganbayan rendered a verdict of acquittal, finding that:

The comparison between the PNP and AFP prices was deficient due to a lack of proper canvass and corroborative evidence from identified suppliers.
The overpricing allegation was not supported by reliably canvassed price quotations, thus failing to establish criminal culpability.
There was no sufficient evidence to prove the alleged conspiracy among the respondents.

The People, through a Rule 45 petition, alleged that the trial court gravely erred in:

Taking judicial notice of certain U.S. laws and applying them to the case without proper basis.
Relying solely on the defense witnesses regarding the existence and effectivity of said U.S. laws.
Failing to appreciate the prosecution’s evidence on the alleged overpricing of the firearms.

The respondents objected to the petition on double jeopardy grounds, contending that an acquittal is a final judgment which bars further prosecution or review, and that any attempt to reopen the case would subject them to repeated punishment for the same offense.

Taking judicial notice of the alleged laws of the United States of America and applying these laws in the context of the present case; and
Relying solely on the testimonies of the defense witnesses concerning the existence and effectivity of those U.S. laws.

Whether or not the court below gravely erred in failing to appreciate the prosecution’s evidence showing beyond reasonable doubt that the PNP paid an overpriced amount of P18,550.30 per unit for 5,681 pistols.

Whether or not the petition, filed under Rule 45, effectively places the respondents in double jeopardy by seeking to reopen proceedings on a matter (a judgment of acquittal) that is legally final and insulated from further prosecution or appeal.