Title
EspiNo. vs. Sandiganbayan
Case
G.R. No. 191834
Decision Date
Mar 4, 2020
NHA officials charged with graft for allegedly overpaying Triad Construction in a housing project; Supreme Court upheld trial proceedings, citing sufficient evidence.

Case Summary (G.R. No. 191834)

Applicable Law

This case is governed by the provisions under the 1987 Philippine Constitution and relevant laws including Republic Act No. 3019. The charges implicate public officials in using their authority to confer undue advantages and benefits to a private contractor, thereby causing damage to government interests.

Case Background

On May 9, 2001, the petitioners were charged for their roles in providing unwarranted benefits to Triad Construction in the context of the Pahanocoy Sites and Services Project in Bacolod City. The information alleged that they made payments significantly exceeding the actual work completed by the contractor, which invited an audit from the Commission on Audit that identified numerous discrepancies.

Procedural History

The trial commenced on June 14, 2004, where the prosecution's witnesses presented evidence, including testimonies from project engineers and auditors. Key witness Candido Montesa Fajutag, Jr. testified about discrepancies in progress billings and the actual work completed. The prosecution presented substantial evidence connecting the petitioners to the alleged misconduct, which culminated in the petitioners filing for Demurrers to Evidence, asserting the prosecution's failure to meet the burden of proof.

Denial of Demurrers and Subsequent Motions

The Sandiganbayan denied the Demurrers to Evidence in a January 29, 2008 resolution, asserting sufficient grounds to proceed with trial. The petitioners sought reconsideration, which was also denied, leading to their filing of separate petitions for certiorari against the Sandiganbayan's resolutions.

Arguments by the Petitioners

The petitioners contended that the Sandiganbayan committed grave abuse of discretion by denying their demurrers, especially in light of the alleged absence of crucial evidence, specifically the "Final Quantification" document that was pivotal to the prosecution's case. Each petitioner proposed arguments centering on the lack of evidence supporting their alleged conspiracy and legal responsibility regarding the payments made to Triad Construction. They asserted that the absence of this document should have led to their acquittal, claiming it was necessary for establishing vital elements of their legal culpability.

Court's Ruling

The Supreme Court dismissed the petitions, ruling that the Sandiganbayan did not exceed its jurisdiction or commit grave abuse of discretion in ordering the petitioners to present their evidence. The Court clarified that a petition for certiorari is limited to q

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