Case Summary (G.R. No. 215104)
Applicable Law
The core legal framework is Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act, which penalizes public officers who cause undue injury to any party or give unwarranted benefits to any private party in their official capacity.
Facts of the Case
The case revolves around two criminal purchases made by the DOH-NCR:
- On May 4, 1996, 10,000 bottles of Paracetamol Suspension were purchased from Aegis Pharmaceuticals at an inflated price.
- On May 13, 1996, 1,500 bottles of Ferrous Sulfate with Vitamin B Complex and Folic Acid were acquired from Lumar Pharmaceutical Laboratory, also above competitive pricing standards.
Anonymous complaints were filed, leading to an investigation and subsequent charges against the involved public officers under Section 3(e) of R.A. No. 3019. The investigation revealed that significant overpricing occurred in both transactions as they lacked proper procurement procedures.
Proceedings
During the trial before the Sandiganbayan, the petitioners maintained their innocence, arguing that the purchases followed established practices in the absence of public bidding, and were in line with policies to reference previous winning bidders' prices. Witness testimonies presented by both the prosecution and defense were analyzed, with findings indicating procedural irregularities in the procurement process.
Sandiganbayan Ruling
The Sandiganbayan issued a decision on April 29, 2014, finding several petitioners guilty of violating R.A. 3019 based on the established facts that they had conspired to facilitate the transactions despite evident overpricing and the absence of public bidding. The court emphasized that such conduct caused undue damage to the government, leading to penalties including imprisonment and perpetual disqualification from public office.
Petitioners’ Arguments
In responding to the Sandiganbayan’s ruling, the petitioners contended that the prosecution failed to prove the essential elements of the crime beyond reasonable doubt. They argued that the lack of public bidding alone should not be sufficient for a conviction, and they acted based on policies that permitted referencing prior pricing when new bids were not available. Specific defenses highlighted their adherence to standard operating procedures during their respective roles.
Supreme Court's Ruling
Upon review, the Supreme Court found the consolidated petitions meritorious and granted acquittal to all petitioners. The Court determined
...continue readingCase Syllabus (G.R. No. 215104)
Case Overview
- The case involves consolidated Petitions for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioners are Eufrocina N. Macairan, Imelda Q. Agustin, Philip F. Du, Rosalinda U. Majarais, Horacio D. Cabrera, Enrique L. Perez, and Anthony M. Ocampo.
- The respondents are the People of the Philippines.
- The case pertains to the conviction of the petitioners for violation of Section 3(e) of Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act.
Facts of the Case
- The Department of Health - National Capital Region (DOH-NCR) made purchases in May 1996 for:
- 10,000 bottles of Paracetamol Suspension 60ml 125mg/5ml.
- 1,500 bottles of Ferrous Sulfate 250mg with Vitamin B Complex and Folic Acid.
- An anonymous letter dated May 15, 1996, led to an investigation into alleged irregularities in these purchases.
- The Office of the Ombudsman found probable cause to charge the petitioners, leading to the filing of Information against them for violations related to the purchases mentioned above.
Procedural History
- The cases were tried jointly before the Sandiganbayan Fifth Division.
- The petitioners entered a not guilty plea during arraignment.
- Stipulations of facts were established for both criminal cases, detailing the positions held by the accused and the nature of the purchases.
- Evidence was presented by both the prosecution and defense, including testimonies from various witnesses.
Evidence for the Prosecution
- Witnesses included