Case Digest (G.R. No. 31703) Core Legal Reasoning Model
Facts:
This case involves the People of the Philippines as petitioner versus the Sandiganbayan (Seventh Division) and Jaime Kison Recio as respondents. The case arose from an Information filed before the Sandiganbayan (SB) charging Jaime Kison Recio, then Executive Director III of the National Parks Development Committee (NPDC), for violation of Section 3 (e) of Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act. The Information, filed around 2017, accused Recio of entering into numerous security service contracts with Variance Protective and Security Agency from 2002 to 2010 without the required public bidding, thus giving unwarranted benefits to Variance. Specifically, the Information alleged that from January 30, 2004 to October 8, 2004, Recio, acting with bad faith and manifest partiality, signed disbursement vouchers amounting to P7,843,54.33 to Variance despite the absence of procurement activities mandated under Republic Act No. 9184. During trial, be
Case Digest (G.R. No. 31703) Expanded Legal Reasoning Model
Facts:
- Parties and Original Case
- The People of the Philippines, through the Office of the Ombudsman (Ombudsman), filed an Information before the Sandiganbayan (SB) against Jaime Kison Recio (Recio), then Executive Director III of the National Parks and Development Committee (NPDC).
- Recio was charged with violation of Section 3 (e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) based on his alleged unlawful entry into numerous security service contracts with Variance Protective and Security Agency (Variance) from 2002 to 2010 without the required public bidding.
- The Information alleged that Recio gave unwarranted benefits to Variance by signing Disbursement Vouchers for security services rendered from January 1 to September 15, 2004, amounting to P7,843,54.33, despite failure to conduct required procurement activities under Republic Act No. 9184.
- Motion for Amendment and Objections
- Before presenting the last prosecution witness on April 4, 2018, the prosecution filed a Motion for Leave of Court to File Amended Information dated March 27, 2018.
- The motion sought to amend the amount from P7,843,54.33 to P7,842,941.60, reflecting the amount in the disbursement vouchers.
- Respondent Recio opposed the motion, arguing the amendment was substantial and prejudicial to his right to be informed of the charges against him.
- Sandiganbayan Resolutions Denying Amendment
- On April 27, 2018, the SB denied the Motion for Leave of Court to File Amended Information, ruling the error in the amount was too substantial to correct after evidence had been presented.
- The SB reasoned the difference was not a mere typographical error because the erroneously stated amount was not spelled out in words and was clearly irregular.
- The Ombudsman moved for reconsideration on May 3, 2018, which the SB again denied on May 22, 2018.
- Petition for Certiorari before the Supreme Court
- The People of the Philippines (Ombudsman) filed a petition for certiorari to assail the SB’s denial of the motion for amendment.
- The core dispute centered on whether the SB gravely abused its discretion by denying the amendment of the Information.
Issues:
- Whether the Sandiganbayan gravely abused its discretion in denying the Ombudsman’s Motion for Leave of Court to File Amended Information to correct the erroneous amount stated in the Information.
- Whether the amendment sought by the prosecution constitutes a substantial amendment prejudicial to the accused’s rights or merely a formal amendment permissible under the Rules.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)