Case Digest (G.R. No. 188165) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Hon. Sandiganbayan, First, Second and Third Divisions & Hernando B. Perez, Rosario S. Perez, Ramon C. Arceo, Jr. and Ernest L. Escaler (G.R. Nos. 188165 & 189063, decided September 29, 2014), the Office of the Ombudsman through its Office of the Special Prosecutor (OSP) sought certiorari relief from the Supreme Court to annul two Sandiganbayan resolutions. In Criminal Case No. SB-08-CRM-0265 (First Division), the Sandiganbayan quashed an information charging respondents with violation of Section 3(b) of Republic Act No. 3019 after finding that the alleged demand of US$2 million did not pertain to any “contract or transaction” within the statute’s scope, following Soriano, Jr. v. Sandiganbayan. In Criminal Case No. SB-08-CRM-0266 (Second Division), it dismissed the robbery charge under Articles 293 and 294 of the Revised Penal Code on the ground of inordinate delay in the Ombudsman’s fact-finding and preliminary investigation, which spanned over fi Case Digest (G.R. No. 188165) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Privilege Speeches and Initial Inquiries
- On November 12, 2002, Rep. Villarama delivered a privilege speech alleging bribery by an unnamed “$2 Million-Dollar Man.” PAGC and Ombudsman inquiries followed.
- Congressman Jimenez corroborated Villarama’s exposé in a November 25, 2002 speech, accusing Justice Secretary Perez of extorting US$2 M in February 2001.
- Ombudsman Fact‐Finding and Preliminary Investigation
- December 23, 2002: Jimenez filed a sworn complaint (OMB-C-C-02-0857L), docketed for criminal and administrative investigation. A Special Panel and FIRO conducted fact‐finding, completed on November 14, 2005.
- November 14, 2005: FIRO filed complaints against Perez, his wife Rosario, Escaler and Arceo for violations of RA 3019, RA 6713, perjury, falsification, and RA 1379. The Special Panel directed respondents to submit counter-affidavits.
- Sandiganbayan Proceedings
- April 18, 2008: Ombudsman filed four informations in Sandiganbayan—
- SB-08-CRM-0265: Violation of RA 3019 § 3(b) (First Division)
- SB-08-CRM-0266: Robbery (Arts. 293, 294 RPC) (Second Division)
- Falsification and other counts (Third and Fourth Divisions)
- May–July 2008: Respondents moved to quash both informations. First and Second Divisions initially denied, then on reconsideration (Nov. 13 & Nov. 20, 2008) quashed and dismissed SB-08-CRM-0265 and SB-08-CRM-0266, respectively.
- Certiorari to the Supreme Court and Consolidation
- State (via OSP) filed petitions for certiorari in G.R. No. 188165 (quash of SB-08-CRM-0265) and G.R. No. 189063 (dismissal of SB-08-CRM-0266).
- Consolidation of related cases occurred in April 2010; two certiorari petitions deconsolidated as moot in February 2013.
Issues:
- Authority
- Whether the Office of the Ombudsman (via OSP) had authority to file certiorari petitions to assail Sandiganbayan resolutions.
- Remedy
- Whether certiorari was the proper remedy versus petition for review on certiorari.
- Specific to G.R. No. 188165
- Whether Sandiganbayan gravely abused discretion by narrowly defining “transaction” in RA 3019 § 3(b) as requiring monetary consideration (per Soriano, Jr.).
- Specific to G.R. No. 189063
- Whether Sandiganbayan gravely abused discretion by finding inordinate delay in the Ombudsman’s proceedings, violating respondents’ right to speedy disposition under Art. III, § 16, Const.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)