A.M. No. RTJ-91-758 - Estoya vs. Abraham-Singson

The Priority Development Assistance Fund (PDAF) scam, also known as the "pork barrel scam," was disclosed by whistleblower Benhur Luy. It involved the misuse of PDAF allocations by lawmakers and private individuals, notably Janet Lim Napoles and her controlled non-governmental organizations (NGOs).
The scheme entailed negotiations between a lawmaker and Napoles for PDAF projects, deciding the implementing NGO and government agency, followed by submission of a "listing" of projects and costs. This listing would be adopted by the lawmaker to request the release of funds via the Department of Budget and Management (DBM).
The DBM issued Special Allotment Release Orders (SAROs) and Notices of Cash Allocations (NCAs), and funds were then released to the NGOs via implementing agencies, such as the Technology Resource Center (TRC).

Mario L. Relampagos (Undersecretary for Operations), Rosario S. NuAez, Lalaine N. Paule, and Marilou D. Bare (all assigned to the Office of the Undersecretary for Operations, DBM) were implicated for processing SAROs and NCAs related to then Congressman Constantino G. Jaraula’s PDAF allocations.
The Commission on Audit (COA) found that P30 million in PDAF funds were transferred via SAROs issued under Jaraula's name from TRC to a dummy NGO, the Countrywide Agri and Rural Economic Development Foundation, Inc. (CARED), controlled by Napoles.
The Office of the Ombudsman, after investigating, found probable cause to charge the respondents for violation of Section 3(e) of R.A. No. 3019 (the Anti-Graft and Corrupt Practices Act) and malversation of public funds.

Multiple criminal cases were filed including Criminal Case Nos. SB-15-CRM-0017 for graft and SB-15-CRM-0020 for malversation, centered on PDAF funds covered by SARO No. ROCS-07-05450.
The Sandiganbayan deferred resolution on probable cause against respondents concerning these two cases because Relampagos denied signing the SARO at issue and requested the prosecution produce a copy of it.
Upon submission of the SARO, the Sandiganbayan found it was signed by DBM Secretary Rolando G. Andaya, Jr., and not by the respondents. Consequently, the court dismissed the cases against them for lack of probable cause by Resolution dated May 13, 2015.
Petitioner’s motion for reconsideration was denied in a Resolution dated July 9, 2015.

Whether the Sandiganbayan gravely abused its discretion in dismissing the criminal cases against respondents Relampagos, NuAez, Paule, and Bare for lack of probable cause regarding SARO No. ROCS-07-05450.
Whether the Sandiganbayan erred by relying solely on the SARO to dismiss the cases, allegedly disregarding other prosecution evidence such as the affidavit of Luy and the COA findings.
Whether certiorari under Rule 65 of the Rules of Court is the proper remedy to question the Sandiganbayan Resolutions dismissing the criminal cases.