Case Summary (G.R. No. 124452)
Antecedents of the Case
The procurement issues arose from three contracts between the PNP and Beltra Industries for the purchase of Caliber .45 Thompson Brand pistols, totaling purchases over P105 million. Allegations surfaced regarding overpricing, prompting the creation of an investigatory committee by then President Fidel V. Ramos, which found no evidence of collusion or overpricing. In contrast, a special audit team by the Commission on Audit noted significant price discrepancies when compared to the Armed Forces of the Philippines' purchasing rates and subsequently led to charges of violating the Anti-Graft and Corrupt Practices Act against the respondents.
Trial Proceedings and Defense
During the trial, the prosecution presented evidence primarily based on audit findings that indicated overpricing in the PNP procurement compared to AFP prices. The defense contended that the AFP's procurement process, utilizing the Foreign Military Sales program, could not serve as a valid basis for price comparison due to differing procurement contexts. Witnesses from the tri-agency committee affirmed the absence of irregularities in the procurement transactions.
Verdict of Acquittal
The Sandiganbayan acquitted the respondents, reasoning that the prosecution failed to demonstrate substantial overpricing as claimed. The court determined that the comparison made with AFP prices was inherently inadequate without a proper canvass of local market prices. The Sandiganbayan emphasized the necessity for a comprehensive price comparison that includes actual market suppliers to substantiate claims of overpricing.
Petition for Review
The People of the Philippines filed a petition for review under Rule 45, requesting a reversal of the acquittal. The key issues raised included alleged judicial notice of US laws, reliance on defense witnesses regarding the legality of certain transactions, and a misapprehension of the evidence presented by the prosecution.
Respondents' Position
The respondents challenged the petition, asserting that the principles of double jeopardy protect them from further prosecution following their acquittal. They maintained that the petition sought to address errors that essentially amounted to reconsideration of the acquittal rather than demonstrating any grave abuse of discretion by the Sandiganbayan.
Court's Ruling
The Co
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Background of the Case
- The People of the Philippines filed a petition for review seeking to reverse the Sandiganbayan's acquittal of the respondents on charges of violating Section 3(g) of Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act.
- The respondents, including Cesar P. Nazareno, Everlino Nartatez, and Nicasio Ma. Custodio, were accused of conspiring in the procurement of firearms under terms grossly disadvantageous to the government.
Contracts and Allegations
- The case arose from three related contracts between the Philippine National Police (PNP) and Beltra Industries for the purchase of Caliber .45 Thompson Brand pistols.
- The contracts were as follows:
- PO No. 081190-654: 2,822 units at P18,550.30 each, totaling P52,348,946.60 (dated November 8, 1990).
- PO No. 0-240-492-185: 1,617 units for P29,995,835.10 (dated April 24, 1992).
- PO No. 0-050-582-153: 1,242 units at a total price of P23,039,472.60 (dated May 5, 1992).
- Allegations of irregularities and overpricing led to a presidential directive for a tri-agency investigation, which ultimately found no overpricing or collusion.
Special Audit Findings
- The Commission on Audit conducted a special audit and found that the PNP's procurement price was significantly higher than the AFP's purchase price for the same firearms, suggesting possible overpricing.
- The audit indicated that the PNP's procurement could have cost P45 million less if purchased at the lower AFP price.
Trial Proceedings
- The prosecution presented members of the special audit team to testify about the alleged overpricing.
- The Sandiganbayan analyzed the price differe