G.R. No. 163788 - Maralit vs. Philippine National Bank

A petition for certiorari under Rule 65 of the Rules of Court was filed by the People of the Philippines seeking the nullification of a Sandiganbayan resolution dated June 23, 2000.
The resolution had quashed the Information in Criminal Case No. 25653 and acquitted respondent Manuel S. Alba of the criminal charge.

On February 17, 1999, Luis G. Pabalan filed an affidavit-complaint with the Office of the Ombudsman against:

Manuel S. Alba, the City Administrator of Quezon City, a high-ranking government official; and
Jeremias T. Cruz, Chairman of Iglesia Evangelica Metodista En Las Islas Filipinas (IEMELIF) and a private individual.

The complaint alleged that the IEMELIF, headed by respondent Cruz, had encroached on Pabalan’s lot by constructing improvements without securing the necessary building permit.
The construction led to a demolition order issued by the Quezon City building official after due notice and hearing.

The Acting Building Official ordered the demolition of the structure, which became final and executory pending the failure of an appeal to the DPWH.
On November 4, 1998, IEMELIF, through respondent Cruz, requested City Administrator Alba to suspend the demolition order pending appeal, arguing its illegality and potential harm to the church.
A memorandum from Alba, dated November 4, 1998, ordered the recall of the demolition order – an action that was taken prior to the building official’s receipt of the appeal letter.
The complainant opposed the recall and requested its revocation, to no avail, thus preventing the demolition from taking effect.

A Graft Investigator, Romeo M. Pamute, was assigned by the Evaluation and Preliminary Investigation Bureau (EPIB) to review the complaint.
Based on the investigation, probable cause was found against the respondent for violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
An Information was filed with the Sandiganbayan on September 9, 1999, charging the respondent with the crime.
The accusatory portion alleged that Alba, while executing his official functions, issued a memorandum recalling the demolition order without proper authority, thereby giving unwarranted preference to respondent Cruz.

On October 4, 1999, the respondent filed a Motion for Leave to Order Reinvestigation and/or Quash the Information, arguing:

The resolution finding probable cause by the Ombudsman was not supported by the facts and evidence; and
The facts recited in the Information were erroneous in substance.

During the hearing, and with no objection from the special prosecutor, the respondent agreed to convert his motion into a motion for reconsideration of the Ombudsman’s resolution affirming probable cause.
Subsequent to filing supporting memoranda and manifesting his position, the respondent’s arraignment was rescheduled twice – first for February 18, 2000, then for March 27, 2000.
On April 10, 2000, despite the pending motion, the respondent was arraigned and pleaded not guilty; he also posted bail for provisional liberty.
On June 23, 2000, the Sandiganbayan issued a Resolution quashing the Information and acquitting the respondent, basing its findings on the delegation of authority under a January 12, 1994 Memorandum from then-Mayor Ismael A. Mathay and a portion of the Graft Investigator’s resolution.

On August 15, 2000, the Special Prosecutor’s Office (SPO) filed a petition for certiorari challenging the Sandiganbayan’s June 23, 2000 resolution.
The petition argued that the Sandiganbayan had committed grave abuse of discretion amounting to lack or excess of jurisdiction by:

Quashing the Information without the respondent’s arraignment or allowing the prosecution to prove its case;
Relying on an outdated mayoral memorandum (January 12, 1994) which had been superseded by Memorandum No. 4; and
Denying the petitioner’s right to due process.

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction when it quashed the Information based on the respondent’s actions under the January 12, 1994 Memorandum.
Whether the delegation of authority to the City Administrator to act on demolition orders was legally valid given that it had been superseded by Memorandum No. 4.

Whether acquitting the respondent before trial and without his explicit prayer for acquittal violated the petitioner’s right to due process.
Whether the dismissal of the case, treated as an acquittal, improperly precluded the prosecution from presenting its case and thus constituted a violation of jurisprudence on due process.

Whether the appellate jurisdiction reposed in the Secretary of Public Works and Highways under Section 307 of Presidential Decree No. 1096 was erroneously transferred to the local chief executive (City Administrator).
Whether the Sandiganbayan’s interpretation and use of the January 12, 1994 Memorandum contravened the applicable provisions of the National Building Code and related administrative guidelines.