Title
Navales vs. People
Case
G.R. No. 219598
Decision Date
Aug 7, 2024
Petitioners, public officers from the Davao City Water District, were charged with graft for bypassing public bidding requirements. However, the Court ruled that prosecution failed to prove bad faith or undue advantage, leading to their acquittal.

Case Summary (G.R. No. 182484)

Applicable Law

The case applies the 1987 Philippine Constitution, particularly focusing on Section 3(e) of Republic Act No. 3019, which addresses corrupt practices of public officers, and stipulates that public officials are penalized for causing undue injury to any party or giving unwarranted advantages to private parties through manifest partiality, evident bad faith, or gross inexcusable negligence.

Summary of Proceedings

The case began with complaints filed in 2005 alleging that the petitioners failed to observe proper bidding procedures in awarding two water supply projects to Hydrock Wells, Inc. The complaints included numerous charges, with specific reference to violations of rules that required competitive public bidding per Presidential Decree No. 1594. Following a lengthy trial and a conviction by the Sandiganbayan in 2015, the petitioners were sentenced to imprisonment and disqualified from holding public office.

Sandiganbayan Findings

The Sandiganbayan found that the prosecution had established the petitioners' public officer status and that they conspired to award contracts to Hydrock, failing to conduct public bidding as required. The court interpreted the actions of the petitioners as having caused unwarranted benefits to Hydrock, thereby meeting the elements required for conviction under Section 3(e).

Petitioners' Defense

In their defense, the petitioners argued that the circumstances of urgency and the lack of qualified bidders justified their decision to bypass the formal bidding process. They maintained that their role was merely recommendatory in nature, ultimately leaving the awarding decision to the DCWD Board of Directors. Additionally, they alleged inadequate representation by their counsel during the trial.

Appeals and Arguments

Post-conviction, the petitioners filed motions for reconsideration and ultimately petitions for review with the Supreme Court, seeking acquittal on the basis that the prosecution had not proven the essential elements of the crime beyond a reasonable doubt. They emphasized the lack of evidence showing manifest partiality or evident bad faith in their actions, and they highlighted their honest belief in the legality of their decisions given the pressing water crisis.

Supreme Court Decision

The Supreme Court granted the petitions, reversing the convictions. The Court established that the prosecution failed to prove beyond reasonable doubt that the petitioners acted with evident bad faith or manifest partiality while performing their duties. It emphasized that

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