Case Digest (G.R. No. 195011-19)
Facts:
Gregorio Singian, Jr. v. Sandiganbayan (3rd Division), The People of the Philippines, and the Presidential Commission on Good Government (PCGG), G.R. Nos. 195011‑19, May 17, 2014, Supreme Court Second Division, Del Castillo, J., writing for the Court.The criminal prosecution arose from an investigation by the Presidential Ad Hoc Committee on Behest Loans and the PCGG into loan accommodations extended by the Philippine National Bank (PNB) to Integrated Shoe, Inc. (ISI). Atty. Orlando L. Salvador filed a sworn complaint with the Office of the Ombudsman (OMB‑O‑96‑0967) alleging that certain PNB officials and ISI officers obtained or facilitated loans that bore the characteristics of “behest loans.” The Ad Hoc Committee’s Fourteenth Report (July 15, 1993) and its Executive Summary listed ISI among corporations given such loans.
The OMB investigation led to Informations charging various persons, including petitioner, with violations of Section 3(e) and Section 3(g) of Republic Act No. 3019 (the Anti‑Graft and Corrupt Practices Act). The Informations were docketed as Criminal Case Nos. 26297 to 26314 and raffled to the Sandiganbayan Third Division. Petitioner, who was ISI’s Executive Vice‑President, pleaded not guilty on January 27, 2004.
Proceedings in the Sandiganbayan produced both dismissals and continuations: on April 29, 2005 the Sandiganbayan dismissed Criminal Case Nos. 26306–26314; deaths of certain accused resulted in further dismissals (e.g., Ingco and Domingo). Trial proceeded on the remaining accounts (Criminal Case Nos. 26297–26305). The prosecution presented nine witnesses (including PCGG and APT custodians, SEC personnel, and PNB managers) and numerous documentary exhibits, notably the Ad Hoc Committee’s Fourteenth Report, the Executive Summary, a January 10, 1972 memorandum from Bautista recommending the letter of credit, and a Deed of Undertaking executed March 24, 1972.
After the prosecution rested, petitioner, with leave, filed a Demurrer to Evidence on February 17, 2010, arguing (1) lack of proof of conspiracy with any PNB official, (2) the contracts were not manifestly and grossly disadvantageous to the government, (3) loans were sufficiently collateralized and ISI had increased capitalization, and (4) petitioner had no overt act or participation; he also attacked admissibility of cert...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioner’s Demurrer to Evidence insofar as the alleged conspiracy element of Section 3(g), R.A. 3019 is concerned, because the public officers purportedly responsible were not charged?
- Did the Sandiganbayan commit grave abuse of discretion in denying the Demurrer given that there is no overt act attributable to petitioner that justifies his inclusion in the alleged conspiracy?
- Did the Sandiganbayan commit grave abuse of discretion in admitting and relying on the Ad Hoc Committee documents (Exhibits C/RR a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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