Case Digest (G.R. No. 239878) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Sandiganbayan (Fifth Division), G.R. No. 239878, decided February 28, 2022, the Office of the Ombudsman’s Task Force Abono filed on July 4, 2011 a complaint against Surigao City officials—Mayor Alfonso Servana Casurra, City Treasurer Leonardo Luib Edera, Jr., City Accountant Jocelyn Eleazar Monteros, City Engineer Maria Separa Geotina, General Services Officer Armando Mapa Elumba, and City Legal Officer Carlo Reynaldo F. Lozada, Jr.—as well as private vendor Rosemarie V. Palacio of Rosa “Mia” Trading. The allegation arose from a 2004 purchase of 3,332 kg of Elements 15-15-30+T.E. foliar fertilizer for ₱1,500 per kilogram—₱4,998,000 in total—without public bidding, resulting in an overpricing of ₱4,495,500, as found in a 2006 COA Notice of Disallowance (amended 2007). After COA post-audit and Task Force investigation, the Ombudsman issued a resolution of probable cause on October 5, 2016 (approved March 22, 2017), and an Information under Section 3... Case Digest (G.R. No. 239878) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Complainants and Respondents
- Task Force Abono of the Office of the Ombudsman filed complaint against respondents: Alfonso Casurra (Mayor), Leonardo Edera Jr. (Treasurer), Jocelyn Monteros (Accountant), Maria Geotina (Engineer/BAC member), Armando Elumba (General Services Officer/BAC member), Carlo Lozada Jr. (Legal Officer/BAC member), and private party Rosemarie Palacio (proprietress of Rosa “Mia” Trading).
- Alleged violation: Section 3(e) of RA 3019 (Anti-Graft Act) and procurement laws in connection with overpricing of fertilizer.
- Transaction and Audit
- In 2004 the City of Surigao received ₱5,000,000 under the DA’s Farm Inputs Program and contracted Rosa “Mia” Trading for 3,332 kg of fertilizer at ₱1,500/kg (total ₱4,998,000) without bidding.
- COA post-audit found overpricing (variance against locally canvassed cost) and issued a Notice of Disallowance in June 2006 (amended March 2007).
- Administrative and Criminal Proceedings
- July 4, 2011 – Task Force Abono filed complaint with OMB for RA 3019 and RA 9184 violations.
- October 5, 2016 – OMB found probable cause for Section 3(e) of RA 3019; approved March 22, 2017.
- May 2, 2017 – Information filed in Sandiganbayan charging Section 3(e) breach.
- Motions, Opposition, and Sandiganbayan Rulings
- Motions to Quash and Defer
- September 22, 2017 – Monteros moved to quash/dismiss and defer arrest and arraignment due to inordinate delay (11 years, 3 months) violating speedy-disposition right.
- September 25, 2017 – Casurra, Edera, Geotina, and Elumba filed omnibus motion to quash; Lozada adopted.
- Prosecution’s Opposition and Sandiganbayan Decisions
- October 19, 2017 – Office of the Special Prosecutor opposed, contending delay was reasonable given complexity and heavy caseload (“Fertilizer Fund Scam”).
- November 27, 2017 – Sandiganbayan granted motions, dismissed case for Section 3(e) RA 3019 violation, citing more than 11 years delay and resulting prejudice.
- April 18, 2018 – Motion for reconsideration denied; added public humiliation and no accused-attributable delay.
- September 7, 2018 – Case dismissed against Palacio.
Issues:
- Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in granting respondents’ motions and dismissing Criminal Case No. SB-17-CRM-1669 for alleged inordinate delay and violation of right to speedy disposition of cases.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)