Facts:

• Sergio O. Valencia challenged the denial of his Demurrer to Evidence in a malversation case.
• The case originated from a complaint filed on July 26, 2011, against Valencia and others, including former President Gloria Macapagal-Arroyo, for alleged irregularities in the use and additional grant of Confidential and Intelligence Fund (CIF) to the Philippine Charity Sweepstakes Office (PCSO).
• Another complaint was filed on December 2, 2011, by PCSO's Board Secretary Eduardo G. Araullo, regarding the illegal and fraudulent release, withdrawal, and disbursement of PCSO's CIF from 2007 to 2010.
• The Office of the Ombudsman found probable cause to indict Valencia and others, except Ermita, for plunder and recommended filing the corresponding information with the Sandiganbayan.
• Valencia's petition for bail was granted on June 6, 2013, as the evidence did not show evident proof of his guilt for plunder.
• After the prosecution presented additional evidence, Valencia filed a Demurrer to Evidence, arguing that the elements of plunder were not established.
• The Sandiganbayan denied his Demurrer on April 6, 2015, and his subsequent Motion for Reconsideration on September 10, 2015, finding sufficient evidence to hold him liable for malversation under Article 217 of the Revised Penal Code (RPC).

Issue:

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Ruling:

• The Supreme Court granted Valencia's Petition for Certiorari.
• The Court set aside the Sandiganbayan's April 6, 2015, and September 10, 2015, Resolutions.
• The Court found that the Sandiganbayan gravely abused its discretion in denying Valencia's Demurrer t...(Unlock)

Ratio:

• The Supreme Court's decision was based on the insufficiency of the allegations in the information to establish the elements of malversation.
• The information did not contain specific factual details necessary to constitute the crime of malversation.
• This omission highlighted the insufficiency of the allegations, the...continue reading