Case Digest (G.R. No. L-46484) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rodrigo Deriquito Villanueva v. People of the Philippines (G.R. No. 218652, February 23, 2022), petitioner Rodrigo D. Villanueva, president and general manager of AM-Europharma Corporation (Europharma) and sole proprietor of Mallix Drug Center (Mallix), participated in a January 15, 2001 public bidding conducted by the Municipality of Janiuay, Iloilo under a Department of Health–League of Municipalities emergency drug procurement program. Despite Europharma’s DOH accreditation having been suspended and the absence of the provincial auditor at bid opening, the municipal Committee on Awards—composed of the mayor, accountant, budget officer, treasurer, and mayor’s representative—proceeded to award contracts worth ₱13,191,223.00 to Europharma and ₱1,744,926.00 to Mallix. Medicines were delivered and accepted the next day without the required 10% performance bond, and payment checks were immediately encashed. A post‐audit by the provincial auditor revealed failures to notify the a Case Digest (G.R. No. L-46484) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Charge
- Rodrigo D. Villanueva (petitioner), President and GM of AM-Europharma Corp. and sole proprietor of Mallix Drug Center, was charged with public officers (Mayor Locsin, Accountant Moreno, Budget Officer Tirador, Treasurer Figueroa, Rep. Minurtio) for violation of Sec. 3(e), RA 3019 (Anti-Graft and Corrupt Practices Act).
- Amended Information alleged that on January 15, 2001, in Janiuay, Iloilo, the accused unlawfully awarded P13,191,223 to Europharma and P1,744,926 to Mallix Drug despite Europharma’s suspended DOH accreditation and undisclosed common ownership by Villanueva, giving unwarranted benefit.
- Factual Antecedents
- Municipal government of Janiuay, under Mayor Locsin as LMP-Iloilo president, received P15 M from DOH for emergency medicines program via MOA dated December 19, 2000.
- Invitation to Bid published; three entities responded (Europharma, Mallix Drug, Pharmawealth). Bidding postponed twice due to absence of provincial auditor.
- January 15, 2001: Committee on Awards opened bids without auditor, recommended award to Europharma and Mallix Drug; Mayor Locsin approved, purchase orders and certificates of acceptance issued January 16; medicines delivered same day; checks issued January 17.
- BFAD testing found P240,000 worth of cotrimoxazole defective; Mallix Drug delivered replacements only on October 16, 2001.
- Provincial auditor’s post-audit revealed: no auditor notification, no performance bond, undisclosed Villanueva ownership, Europharma accreditation suspended.
- Ombudsman-Visayas investigation found probable cause; petition for review on certiorari filed in Supreme Court challenging Sandiganbayan’s February 23, 2015 Decision and June 8, 2015 Resolution convicting petitioner and co-accused.
Issues:
- Whether the Sandiganbayan convicted for offenses not stated in the Amended Information.
- Whether conviction under COA Circular No. 92-386 is improper, as it is not penal law.
- Whether the award was valid under “emergency procurement” doctrine.
- Whether Sec. 368, LGC, allowed bypassing public bidding.
- Whether LMP-Iloilo’s corporate personality barred treating actions as municipal functions.
- Whether acceptance of Pharmawealth’s disclaimer was erroneous.
- Whether Europharma’s pending license renewal disqualified it as bidder.
- Whether DOH accreditation was a legal requirement for local procurement.
- Whether piercing the corporate veil of Europharma and Mallix Drug was improper.
- Whether conspiracy findings based on circumstantial evidence violated the equipoise doctrine.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)