G.R. No. 201117 - Beltran vs. Sandiganbayan, 2nd Division

The case involves a Petition for Certiorari filed by petitioners Romeo A. Beltran and Danilo G. Sarmiento against the Sandiganbayan, the Office of the Ombudsman, and other related parties.
The Office of the Deputy Ombudsman found Beltran guilty of serious dishonesty, leading to his dismissal from government service and the recommendation of criminal charges against both petitioners.
The case originated from a complaint filed by the Commission on Audit regarding a contract for a farm-to-market road project that was allegedly not completed as certified by Beltran.

The Office of the Deputy Ombudsman determined that Beltran falsely certified the completion of a project that was only 3.78% finished.
The investigation revealed discrepancies between the Commission on Audit’s Inspection Report and the certifications provided by local barangay captains.
Beltran's reliance on these certifications was deemed misplaced as they were issued significantly after the inspection report.

Beltran contended that he was not a disbursing officer and had acted based on his observations when certifying the project as complete.
He invoked the presumption of regularity in the performance of his official duties and presented certifications from barangay captains asserting the road's completion.
Beltran argued that the findings of the Fact-Finding Team supported his claims regarding the project's status.

The Office of the Deputy Ombudsman ruled against Beltran, stating that he failed to provide sufficient evidence to refute the claim of falsification.
It concluded that Beltran's actions caused significant financial damage to the municipality, amounting to P9,622,000.00.
The Office recommended criminal charges against both Beltran and Sarmiento, while dismissing administrative charges against Sarmiento and Mayor Castillo.

Following the Deputy Ombudsman’s decision, Informations for the recommended violations were filed in the Sandiganbayan.
Beltran and Sarmiento sought to postpone their arraignment, citing a pending Motion for Reconsideration with the Office of the Deputy Ombudsman.
The Office of the Special Prosecutor issued an Order that was interpreted by Beltran as a denial of his Motion for Reconsideration.

Petitioners argued that the Office of the Special Prosecutor lacked the authority to deny the Motion for Reconsideration and that the February 1, 2011 Order was not a final decision.
They claimed that the Office of the Deputy Ombudsman had disregarded their evidence and committed grave abuse of discretion in finding probable cause.
Petitioners maintained that the certifications from barangay captains should have been given more weight due to their proximity to the project.

Respondents contended that the issue regarding the Office of the Special Prosecutor's authority had become moot due to the subsequent May 9, 2012 Order, which explicitly denied the Motion for Reconsideration.
They argued that the Office of the Deputy Ombudsman acted within its discretion and did not commit grave abuse in finding probable cause against the petitioners.
Respondents emphasized that the findings of the Office of the Ombudsman should not be disturbed without evidence of arbitrariness.