Case Summary (G.R. No. 144760-61)
Applicable Law
The key legislation involved in the case includes Republic Act (R.A.) No. 3019, specifically Section 3(g), which addresses corrupt practices of public officers, as well as COA Circular No. 85-55A, which governs procurement processes in government transactions.
Factual Background
In August 1990, Nava, the DECS Region XI Director, in a meeting with superintendents, decided to sub-allot P9.36 million intended for nationalized high schools for the procurement of SLTDs without public bidding, citing urgency to utilize the funds before year-end. The DECS-Davao Oriental subsequently procured SLTDs from D'Implacable Enterprises, resulting in payments that were reported to be significantly higher than prevailing market rates. Following a special audit by the Commission on Audit (COA), evidence was gathered alleging that the procurement resulted in a loss to the government of nearly P400,000.
Sandiganbayan Proceedings
The Sandiganbayan found probable cause against Miranda, Nava, Obenza, and others for violations of RA 3019, leading to the filing of criminal cases. The Sandiganbayan’s decisions on January 10, 2005, found Miranda and the other accused guilty of overpricing and sentenced them to prison terms, disqualification from public office, and required them to indemnify the government for losses incurred.
Petition for Certiorari and Appeals
Miranda and Nava filed separate petitions for certiorari, claiming grave abuse of discretion by the Sandiganbayan in denying motions to quash the information against them and asserting that the decisions deviate from established jurisprudence. They contended that the audit team's methodology was flawed, particularly regarding the determination of overpricing and conspiracy.
Ruling on Miranda’s Motion to Quash
The denial of the motion to quash was challenged by Miranda, who argued that there were no plain, speedy, and adequate legal remedies available to her. However, the court found that she opted not to pursue a motion for reconsideration, which was deemed a necessary step before filing a certiorari. The court underscored that the denial of a motion to quash is interlocutory and not subject for immediate appeal.
Ruling on Sandiganbayan Decisions
In evaluating the decisions of the Sandiganbayan, the Supreme Court noted that mere claims of overpricing without sufficient evidence do not warrant conviction under RA 3019. The court stated that errors of judgment by the Sandiganbayan do not equate to grave abuse of discretion, which is only recognized where conduct is arbitrary or capricious.
Audit Team’s Methodology
The audit team's report was critically examined, focusing on
...continue readingCase Syllabus (G.R. No. 144760-61)
Case Background
- This case involves consolidated petitions involving several parties, including Evelyn L. Miranda, Venancio R. Nava, and Primo C. Obenza, against the Sandiganbayan and the Office of the Ombudsman.
- The case concerns allegations of corruption and violation of Republic Act No. 3019, specifically Section 3(g), which deals with contracts grossly and manifestly disadvantageous to the government.
- The consolidated cases were filed under G.R. Nos. 144760-61 (Miranda's petition for certiorari and prohibition), G.R. Nos. 167311-12 and 167625-26 (appeals by Miranda and Obenza), and G.R. Nos. 167316-17 (Nava's petition for certiorari).
- The Sandiganbayan found the accused guilty and imposed penalties including imprisonment and perpetual disqualification from public office.
The Facts of the Case
- In August 1990, an agreement was made by Nava and school superintendents to sub-allocate a P9.36 million allotment from the Department of Education, Culture and Sports (DECS) for purchasing science laboratory tools and devices (SLTDs) without public bidding.
- The procurement occurred through D'Implacable Enterprises, owned by Antonio S. Tan, where Miranda served as the sales representative.
- An audit by the Commission on Audit (COA) revealed that the prices paid for the SLTDs were significantly inflated, resulting in a loss to the government amounting to P398,962.55.
- The Ombudsman found probable cause for the allegations of overpricing and filed criminal cases against Nava, Obenza, Austero, Tan, and Miranda.
The Ruling of the Sandiganbayan
- On January 10, 2005, the Sandiganbayan found Nava, Obenza, Tan, and Miranda