G.R. No. 101421 - Torralba vs. Sandiganbayan

On June 14, 1990, Felix T. Rengel, a member of the Sangguniang Panlalawigan of Bohol, filed a complaint with the Office of the Ombudsman for the Visayas.
The complaint charged a conspiracy involving the overpriced purchase of two Nissan double-cab pick-ups by the provincial government.
The respondents named were:

Torralba denied the allegations, asserting that the purchase was regular, necessary, reasonable, and confirmed by the pre-audit and post-audit reports of the Commission on Audit (COA).
Alexander H. Lim clarified his participation, averring that his only involvement was signing the Requisition and Issue Voucher (RIV) for the payment of the vehicles, and he disclaimed any engagement in the canvassing, bidding, or other procedural aspects.

On October 18, 1990, the Office of the Ombudsman for the Visayas issued an order directing the petitioners and their co-respondents to answer several interrogatories.
Torralba and Lim complied by responding on October 15 and October 22, 1990, respectively.
Director Vicente Y. Varela, Jr. issued a resolution on October 26, 1990, recommending the dismissal of the complaint for lack of prima facie evidence.
The records were subsequently forwarded to the Office of the Ombudsman in Manila for review.
On February 12, 1991, Rengel, through counsel, filed a manifestation urging that the audit report of the Provincial Auditor of Bohol be included in the case, claiming it demonstrated an overprice of P85,756.00 – a report which had been submitted later on December 19, 1990.

On May 20, 1991, Agapito B. Rosales, Director of the Fact-Finding and Intelligence Bureau of the Office of the Ombudsman, issued a resolution with the following recommendations:

Filing of an information against Torralba for a prima facie case of violating Section 3, paragraph (g) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act).
Dismissal of the charges against Alexander H. Lim, Manuel Navarro, and Christopher Lim for lack of evidence of conspiracy.
Initiation of administrative action by the Commission on Audit.

Based on the above, and after modifications approved by the Ombudsman’s special prosecution officer, an information was filed against all the respondents, including Torralba, under Criminal Case No. 16914.
On July 24, 1991, Torralba filed motions to quash his arrest warrant and for a reinvestigation of the case, which were later adopted by Lim.
The motions were premised on the allegation that there was no valid preliminary investigation prior to issuing the arrest warrant and that the petitioners were not furnished copies of the resolutions and accompanying audit report.

On August 2, 1991, the Sandiganbayan denied the motions to quash the arrest warrant and for reinvestigation, setting the arraignment for September 9, 1991.
Torralba filed a motion for reconsideration and an urgent motion to suspend the arraignment, emphasizing that the audit report surfaced only after the case had been transmitted for review, and noting the non-receipt of key documents.
On September 4, 1991, the Sandiganbayan issued a resolution denying both the reconsideration and the urgent motion, asserting that:

The accused were aware of the COA Report and its legal consequences.
The procedural rules provided for a single motion for reconsideration to be filed within fifteen (15) days from receipt of notice, and that the petitioners had already availed of this opportunity when they filed their initial motion on July 23, 1991.

Subsequently, on September 5, 1991, separate petitions for certiorari, prohibition, and mandamus were filed by Torralba and Lim.
A temporary restraining order was issued, enjoining the Sandiganbayan from proceeding with the arraignment of the petitioners.
The petitioners contended that the denial to furnish them with the final resolutions and the audit report deprived them of their right to a full preliminary investigation.

Whether the petitioners were denied their substantive right to a full preliminary investigation, a right that forms an indispensable part of due process in criminal proceedings.
Whether the failure to furnish the petitioners with copies of the final resolutions, including the modified memorandum of SPO Lantion and the special audit report, amounted to a violation of the procedural requirements set forth in the Ombudsman's Rules of Procedure under Republic Act No. 6770.
Whether the procedural deficiencies in the preliminary investigation adversely affected the validity and jurisdiction of the criminal information filed against the petitioners.
Whether the Sandiganbayan should have granted the petitioners’ motion for reinvestigation in view of the alleged denial of their right to fully contest and examine the evidence against them.