G.R. No. 189026 - Philippine Telegraph and Telephone Corp. vs. Smart Communications, Inc.

Petitioner Edelbert C. Uyboco and co-accused were charged in Sandiganbayan Criminal Case No. 24461 for violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), alleging conspiracy to cause undue injury to the government in the procurement of dump trucks.
On January 9, 2014, the Sandiganbayan rendered a decision finding petitioner guilty beyond reasonable doubt; on March 14, 2014, it denied his motion for reconsideration and plea to reopen proceedings based on alleged incompetence of counsel.

Accused Rodolfo G. Valencia, as provincial governor, entered into a negotiated contract with Gaikoku (owned by petitioner) for the purchase of dump trucks at ₱6,994,286 without prior resolution of the Sangguniang Panlalawigan and without the required two failed public biddings under Section 369 of the Local Government Code.
The Provincial Government could have imported the trucks tax-free at ₱4,594,119.85, resulting in an overpayment of ₱2,400,166.15, constituting undue injury to the government.
The Sandiganbayan held that petitioner, though a private individual, conspired with Valencia by participating in and approving purchase documents, thereby facilitating the corrupt transaction.

Whether the Sandiganbayan erred in finding conspiracy and convicting petitioner absent proof beyond reasonable doubt.
Whether the denial of petitioner’s motion to reopen proceedings on grounds of counsel’s alleged gross incompetence violated his constitutional right to due process and competent counsel.
Whether the petition for review on certiorari raised only questions of law, as required under Rule 45 of the Rules of Court.