G.R. No. 87186 - Villa vs. Sandiganbayan

In 1975, an investigation was launched into anomalous transactions at the Civil Aeronautics Administration (CAA), Mactan International Airport following questionable payments made to certain suppliers.
Criminal charges were filed in the Circuit Criminal Court of Cebu City against several employees—including Casimiro David (administrative assistant and chairman of the bidding committee), Estanislao Centeno (cash aide), Fernando Dario (airport attendant), and Serafin Robles (janitor)—for violations of Section 3, paragraphs (a) and (h) of R.A. 3019, as well as various administrative regulations such as the Unnumbered Presidential Memorandum dated April 22, 1971, Section 12 of Rule XVIII of the Civil Service Rules, and Section 1(x) of Presidential Decree No. 6.

The case centered on the purchase of electrical items for the Mactan Airport involving Rocen Enterprises and Sprayway Corp., with a total transaction value of P299,175.00.
The procurement process involved multiple steps:

Requisition and issuance of a voucher for the articles by Montayre on June 1, 1975.
Approval of the requisition by Airport General Manager Arturo Jimenez and certification of funds by Chief Accountant Hereto Leonor.
The canvassing of bids, wherein a sealed bidding process was conducted on June 25, 1975, resulting in the awarding of the contract to Rocen Enterprises—a supplier whose reputation was questionable as its business was limited to paper products and printed matters.
Preparation of inspection reports, certificates of delivery, and issuance of treasury warrants even before the actual delivery of the electrical items (which were eventually delivered on July 6, 1975).

Arturo Jimenez – Airport General Manager, who approved the purchase and oversaw the bidding process despite knowing some of the negotiating parties.
Rodolfo Montayre – Assistant Airport General Manager, who executed requisitions and signed pertinent documents under the emergency context of a brownout.
Camilo Villa – Chief of the Logistics Section and member of the Bidding Committee, responsible for determining the items needed and processing vouchers.
Josefina Sucalit – Technical Inspector from the COA, tasked with canvassing suppliers in Manila and pre-auditing the documentation, despite her involvement in delivering advertisement forms to an unsuitable supplier.
Hereto Leonor – Chief Accountant, whose role was to certify funds and sign off on the financial documents.

In addition, the trial court had found that these officials were in conspiracy with those already convicted in another related case (Criminal Case No. CCC-XIV-1457), namely David, Centeno, Dario, and Robles.

On October 20, 1978, the Circuit Criminal Court of Cebu City, presided by Judge Romeo Escareal, found the accused guilty of multiple violations of Section 3 (paragraphs (a), (e), (h), and (i)) of R.A. 3019.
All accused appealed the judgment to the Court of Appeals, which reversed the conviction against the first group of accused in Criminal Case No. CCC-XIV-1457 on grounds of insufficient evidence.
A separate investigation led to the filing of Criminal Case No. 5915 before the Sandiganbayan involving Jimenez, Montayre, Villa, Sucalit, Leonor, and the previously convicted employees.
The Sandiganbayan conducted its own trial, consolidated several petitions (filed by Villa, Montayre, Sucalit, and Jimenez), and faced issues including motions for reconsideration and challenges regarding the application of the doctrine of “the law of the case” as well as res judicata.

Documentary evidence such as requisition and issue vouchers, inspection reports, certificates of delivery, and treasury warrants indicated that the documents were signed even before the delivery of equipment.
Testimonies revealed that:

The procurement was executed in an emergency context due to a brownout, necessitating quick action before the expiry of Cash Disbursement Ceilings (CDCs).
Despite the emergency, the process bypassed the usual verification of supplier reputability, with Rocen Enterprises—represented by individuals with known connections (Centeno, Robles, and Dario)—being awarded the contract.
There were irregularities such as an unexplained overcharge of P27,100 meant to cover installation costs, despite evidence suggesting that installation was carried out by other personnel.

Whether the decision of acquittal rendered by the Court of Appeals in Criminal Case No. CCC-XIV-1457 (six months before the Sandiganbayan’s judgment) should act as “the law of the case” to automatically bar conviction in the present proceedings.
Whether the credibility of the prosecution’s witnesses—previously discredited as biased by the Court of Appeals—should be given due weight by the Sandiganbayan.
Whether there was a conspiracy among the petitioners and their co-conspirators in the procurement process, despite the reversal of the earlier charges.
Whether the principle of res judicata, requiring substantial identity of parties, should prevent a conviction in the Sandiganbayan case given the similarities with the reversed Circuit Criminal Court decision.