Case Digest (G.R. No. 239746) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Camilo Loyola Sabio v. Sandiganbayan, G.R. Nos. 233853-54, decided on July 15, 2019 under the 1987 Constitution, the Presidential Commission on Good Government (PCGG) entered into two lease agreements with UCPB Leasing and Finance Corporation (a sequestered entity administered by PCGG). On April 18, 2007, five (5) service vehicles were leased for ₱5,393,000.00, and in 2009 six (6) service vehicles were leased for ₱6,734,610.00, both without public bidding in violation of Republic Act No. 9184 (Government Procurement Reform Act). In November 2012, the Office of the Ombudsman’s Field Investigation Office filed criminal complaints for violation of Section 3(e), R.A. 3019 (Anti-Graft and Corrupt Practices Act) anchored on lack of competitive bidding and absence of appropriations for the leases. Informations were lodged in Sandiganbayan Criminal Case Nos. SB-12-CRM-0014 and SB-12-CRM-0015 on February 13, 2014, charging Sabio and four PCGG commissioners. By Resolution of May 29, 20 Case Digest (G.R. No. 239746) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Lease Agreements
- On April 18, 2007, the Presidential Commission on Good Government (PCGG) and United Coconut Planters Bank Leasing & Finance Corporation (UCPB Leasing) executed a Lease Agreement for five (5) motor vehicles.
- In 2009, the PCGG and UCPB Leasing entered into another (undated) lease contract for six (6) service vehicles—both contracts were negotiated procurement without public bidding.
- Initiation of Criminal Proceedings
- In November 2012, the Field Investigation Office of the Office of the Ombudsman filed criminal cases against PCGG Chairman Camilo L. Sabio and Commissioners Ricardo M. Abcede, Tereso L. Javier, Narciso S. Nario, and Nicasio A. Conti for violation of Section 3(e), R.A. No. 3019, and R.A. 9184.
- On February 13, 2014, Informations in SB-12-CRM-0014 (five vehicles, P5,393,000) and SB-12-CRM-0015 (six vehicles, P6,734,610) were filed in the Sandiganbayan.
- Pre‐Trial Proceedings
- May 29, 2014: Sandiganbayan dismissed charges against Javier, Nario, Conti (speedy trial right) and noted Abcede’s death; Sabio remained the sole accused.
- January 28, 2015: Sabio arraigned and pleaded not guilty; parties stipulated to facts regarding Sabio’s public-office roles and UCPB’s sequestered status.
- Trial and Evidence
- Prosecution witnesses (6):
- Marita Villarica and Romulo Siazon—authenticated Sabio’s appointment and service records.
- Corinne Joie Carillo—conducted fact‐finding; found no appropriation or bidding for the 11 vehicles.
- Teresita Avante-Rosal—BAC secretary; no bidding for vehicle leases (2006–2009).
- Marcial Flores—certified absence of vehicle‐purchase funds (2007–2008).
- Irma Carlos—accounting clerk; testified on vehicles issued to Sabio and their transfer after lease termination.
- Defense testimony—Sabio claimed:
- PCGG is sui generis and exempt from procurement law;
- He acted as the President’s alter ego;
- Lease‐purchase practice existed prior to his term; no personal gain was involved.
- Sandiganbayan Decision and Subsequent Proceedings
- June 22, 2017: Sabio found guilty of two counts under Section 3(e), R.A. 3019; sentenced to indeterminate 6 years 1 month to 10 years each count, plus perpetual disqualification.
- August 25, 2017: Motion for reconsideration denied.
- Sabio filed a Rule 45 petition, raising: (A) PCGG’s alleged exemption from procurement law; (B) his alleged presidential immunity; and (C) alleged reversible error in conviction.
Issues:
- Whether the PCGG, being sui generis, is exempted from the requirements of the Government Procurement Reform Act (R.A. 9184).
- Whether Sabio, as alter ego of the President, is immune from suit.
- Whether the Sandiganbayan erred in finding Sabio guilty of violating Section 3(e) of R.A. 3019.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)