Case Summary (G.R. No. 175836)
Factual Antecedents
The case originates from complaints against Mayor Eugenio Caballero and other municipal officials regarding alleged violations of the Anti-Graft and Corrupt Practices Act in connection with procurement transactions during Caballero’s term in 1993. A public bidding for necessary materials and catering services led to contracts awarded to Caballero's wife's businesses—GP's Food Catering Services and Genty General Merchandise. A subsequent complaint filed by Crisologo Decierdo claimed these awards amounted to unlawful benefits procured due to the Mayor’s position.
Investigation Findings
State Auditor Leonilo Morales conducted an investigation and determined that the bidding process had been followed properly without Mayor Caballero’s influence on the outcome. Morales recommended dismissal of the complaint, citing procedural compliance and a lack of evidence of any impropriety on the part of the officials involved. However, this conclusion was overturned by the Ombudsman which found prima facie evidence against the petitioners and charged them, leading to the issuance of four information regarding violations of the Anti-Graft Law.
Motion to Quash
The petitioners subsequently filed a motion to quash the information, asserting that the facts charged did not constitute an offense. They emphasized the prosecutor's recommendation to quash the motions based on the same reasoning that Mayor Caballero’s conduct and involvement did not meet the legal criteria for a violation of the Anti-Graft Law.
Sandiganbayan's Rulings
The Sandiganbayan denied the motion to quash, determining that the allegations positioned Mayor Caballero as having intervened in favor of his wife's businesses due to his position as a public officer and his financial interest in the businesses. The court maintained that the facts charged sufficiently established a basis for charges of corruption.
Grounds for Petitioners' Appeal
The petitioners argued that the Sandiganbayan committed grave abuse of discretion by denying the motion to quash on grounds that the information failed to state an offense due to lack of established evidence that Mayor Caballero intervened improperly in the awarding of the contracts.
Jurisdiction of the Sandiganbayan
With respect to jurisdiction, the petitioners contended that they were not within the Sandiganbayan's jurisdiction as municipal mayors were not specifically listed in the law governing the court's jurisdiction over corrupt practices. However, jurisprudence, particularly the decision in Binay v. Sandiganbayan, indicated that municipal mayors do indeed fall under the jurisdiction of the Sandiganbayan due to their classification under applicable salary grades devised in the Compensation and Position Classification Act.
Legal Interpretation of Financial Interest and Intervention
The Supreme Court interpreted the requirements under Section 3(h) of the Anti-Graft Law allowing for criminal liability when public officials utilize their positi
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Case Overview
- This case involves a joint petition for certiorari and prohibition under Rule 65 of the Rules of Court, filed by the petitioners to challenge the resolutions of the Sandiganbayan dated December 8, 1998, and February 12, 1999.
- The petitioners include Eugenio U. Caballero, the mayor of the Municipality of Manukan, Zamboanga del Norte; Ma. Theresa G. Caballero, his wife and owner of GP's Food Catering Services and Genty General Merchandise; and Nerita Cuento, the municipal accountant.
- The main objective of the petition is to set aside the Sandiganbayan's denial of the motion to quash the informations against them and to prohibit the court from proceeding with the criminal cases.
Factual Antecedents
- In 1993, during Mayor Caballero's incumbency, the Municipality of Manukan conducted committee hearings on tax ordinances and a seminar-workshop requiring the purchase of materials and catering services.
- A public bidding was held where GP's Food Catering Services and Genty General Merchandise, owned by Ma. Theresa Caballero, were awarded contracts as the lowest bidders.
- A complaint was subsequently filed by Crisologo Decierdo against the involved municipal officials for violations of the Anti-Graft and Corrupt Practices Act (RA No. 3019), alleging they unlawfully secured benefits for the mayor and his wife.
- State Auditor Leonilo Morales conducted an investigation and reported that the bidding process was conducted properly, recommending the dismissal of the complaint against the petitioners.
Investigation and Ombudsman Proceedings
- Despite the State Auditor's findings, the Office of the Ombudsman-Mindanao continued the investigation, eventually finding a prima facie case for violations of Section 3(h) of RA No. 3019.
- Four informations were filed against the petitioners and one Semie Torres before the Sandiganbayan for violations alleging financial interests in contracts aw