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
...continue readingCase Syllabus (G.R. No. 182484)
Background and Parties Involved
- The case concerns two consolidated petitions for review on certiorari filed by Arnold D. Navales, Rey C. Chavez, Rosindo J. Almonte, Alfonso E. Laid, and William Velasco Guillen, petitioners who were officials of the Davao City Water District (DCWD).
- Navales, Chavez, and Guillen were members of the Pre-Bidding and Awards Committee-B (PBAC-B).
- Almonte was the Division Manager of the DCWD Engineering and Construction Department; Laid was the Assistant General Manager for Administration.
- The Sandiganbayan found petitioners guilty of violating Section 3(e) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act.
The Project and Contract Award
- The DCWD Board of Directors approved undertaking the Cabantian Water Supply System Project with an overall budget of PHP 33,200,000.00.
- The initial phase involved well drilling simultaneously for two wells (VES 15 and VES 21 Projects), budgeted at PHP 4,000,000.00 each.
- Hydrock Wells, Inc. (Hydrock) was recommended by DCWD General Manager Wilfredo A. Carbonquillo for direct negotiation for the project.
- PBAC-B dispensed with the advertisement requirement and invited bids only from accredited well drillers, with Hydrock being among those who responded.
- Hydrock was recommended for and eventually awarded the projects on negotiated contracts without public bidding.
Charges and Proceedings
- Multiple complaints were filed alleging violations of Section 3(e) of Republic Act No. 3019 and grave misconduct for failing to observe proper bidding procedures.
- Petitioners were charged for dispensing with competitive public bidding as required by Presidential Decree No. 1594.
- The Amended Information specifically accused petitioners of conspiring to unlawfully give unwarranted benefits to Hydrock by awarding the VES 21 Project through negotiated contracts without legal basis.
- Petitioners pleaded not guilty and trial ensued.
Prosecution and Defense Presentation
- Prosecution evidence showed invitations to accredited drillers were sent instead of public advertisements.
- PBAC-B recommended contract awards to Hydrock despite the lack of proper public bidding and allowed project commencement before formal notices were issued.
- Petitioners contended exceptions to public bidding existed due to urgency, failure of competitive bidding, and lack of qualified bidders.
- They emphasized their recommendatory role to the DCWD board, which held the authority to award the contract.
Sandiganbayan Decision and Sentencing
- The Sandiganbayan convicted petitioners, finding them guilty beyond reasonable doubt of violating Section 3(e) of RA 3019.
- The court found that petitioners acted with evident bad faith and manifest partiality, conspiring to award the project to Hydrock, thus circumventing the mandated public bidding.
- The acts supposedly gave Hydrock unwarranted advantage and benefits.
- Petitioners were sentenced to imprisonment ranging from six years and one month to ten years, plus perpetual disqualification from holding public office.