Case Summary (G.R. No. 236408)
Facts of the Case
The charges against Baterina arise from the PDAF cases against Mario Relampagos and others. A complaint filed by the National Bureau of Investigation (NBI) in 2013 prompted an investigation into Baterina’s utilization of PDAF allocations for 2007. The NBI-Baligod Complaint alleged misuse of funds allocated through several Special Allotment Release Orders (SAROs), which were transferred to non-government organizations (NGOs) for purported livelihood projects. Following an investigation by the Office of the Ombudsman (OMB), Baterina was indicted on charges that included violations of the Anti-Graft and Corrupt Practices Act and Malversation under the Revised Penal Code.
Legal Proceedings and Motions
After the issuance of a Joint Resolution by the OMB finding probable cause for the indictment, Baterina filed a Motion for Reconsideration, which was denied. Subsequently, he sought to quash the filed Informations through an Omnibus Motion before the Sandiganbayan, asserting violations of his constitutional rights and flaws in the OMB's preliminary investigation process. This motion was dismissed, and the denial was upheld upon reconsideration.
Grounds for the Petition
Baterina's petition was based on several grounds alleging grave abuse of discretion amounting to a lack of jurisdiction by the Sandiganbayan. He contended that the OMB exceeded its authority in ordering further investigations after already initiating a preliminary investigation. He also claimed he was denied due process, asserting that non-receipt of his Counter-Affidavit violated his rights and that bias existed within the investigative body.
Arguments of the Petitioner
Baterina asserted that the OMB's dual investigations—initially by the NBI and subsequently by the Field Investigation Office (FIO)—were improper as they intertwined findings of the preliminary investigations in a manner that prejudiced him. He claimed that the OMB's actions constituted a failure to respect his right to challenge the accusations against him and that the time taken to file the cases constituted an unreasonable delay, justifying the petition's review.
Court's Ruling
The Court found that the Sandiganbayan’s rulings affirming the OMB's authority to conduct additional investigations were correct. It stated that the OMB retains the discretion to evaluate complaints and recommend necessary investigations without being bound by prior findings of fact by the NBI. The Court underscored that the functions of OMB are executive in nature and involve determining probable cause based on comprehensive evidence. Therefore, the OMB was within its rights to conduct further investigations despite any earlier complaints.
Due Process and Speedy Disposition of Case
The Court also ruled that there was no violation of Baterin
...continue readingCase Syllabus (G.R. No. 236408)
Overview of the Case
- The case involves a Petition for Certiorari under Rule 65 of the Rules of Court.
- Petitioner: Salacnib F. Baterina.
- Respondent: The Sandiganbayan, Second Division.
- Relevant Resolutions: Dated September 22, 2017, and December 12, 2017, which denied the petitioner’s Omnibus Motion to quash seven criminal Informations.
- Criminal Cases Involved:
- Violations of Section 3(e) of Republic Act No. 3019.
- Malversation of Public Funds under Article 217 of the Revised Penal Code.
- Direct Bribery under Article 210 of the Revised Penal Code.
Antecedents of the Case
- The case stems from Priority Development Assistance Fund (PDAF) allegations against several lawmakers, including the petitioner, who served as a Representative from 1998 to 2007.
- A complaint was filed by the National Bureau of Investigation (NBI) on November 29, 2013, regarding the misuse of the petitioner’s PDAF allotment for 2007, totaling P35,000,000.00.
- The funds were allegedly released to the Technology Resource Center (TRC) via Special Allotment Release Orders (SAROs) and were transferred to various foundations for livelihood projects.
- Subsequent investigation and complaints led to the Office of the Ombudsman (OMB) finding probable cause against the petitioner and filing seven Informations on March 17, 2017.
Grounds for the Petition
- Petitioner argues that the Sandiganbayan acted with grave abuse of discretion in various aspects:
- Jurisdiction over