Case Summary (G.R. No. 223654-55)
Applicable Law
The case involves the violation of Section 3(e) of Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act, and Article 237 of the Revised Penal Code (RPC). The relevant procurement law is Republic Act No. 9184, also known as the Government Procurement Reform Act.
Antecedents of the Case
The charges arose from allegations that Roxas and Trinidad illegally reconvened the former Pre-Qualification Bids and Awards Committee (PBAC) to conduct a public bidding while knowing that a new Bids and Awards Committee (BAC) had been established under RA 9184. The prosecution contended that Roxas and Trinidad's actions demonstrated manifest partiality, evident bad faith, and gross inexcusable negligence, effectively leading to unwarranted benefits for Izumo Contractors, Inc.
Prosecution's Case
The trial included testimonies from multiple witnesses, including Graft Investigation Officer Luisito S. Suarez and City Treasurer Concepcion C. Daplas. They established that the bidding process did not comply with the necessary public procurement regulations and that the former PBAC had been dissolved before the bidding occurred.
Sandiganbayan's Ruling
On November 26, 2015, the Sandiganbayan found Roxas and Trinidad guilty beyond a reasonable doubt of the charges against them and sentenced them to imprisonment and perpetual disqualification from public office. The court ruled that their actions constituted corruption and an abuse of authority as they continued to exert powers beyond their authority as members of a defunct committee.
Motions for New Trial
After the decision, Roxas filed an Omnibus Motion for a new trial and reconsideration, claiming that his previous counsel's errors deprived him of his opportunity to defend himself effectively. The Sandiganbayan denied this motion, asserting that Roxas was informed of the legal processes and voluntarily participated in the trial.
Court’s Analysis of Motions
The Supreme Court upheld the Sandiganbayan’s decision, emphasizing that Roxas's participation in the proceedings and the ability to file a demurrer to evidence indi
...continue readingCase Syllabus (G.R. No. 223654-55)
Background of the Case
- The case revolves around a Petition for Review on Certiorari filed by Jose Antonio F. Roxas (Roxas) contesting the decision of the Sandiganbayan dated November 26, 2015.
- Roxas was found guilty of violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) and Article 237 of the Revised Penal Code (RPC).
- The petition also challenges the Sandiganbayan's Resolution dated March 7, 2016, which denied Roxas's Omnibus Motion for New Trial and Motion for Reconsideration.
Antecedents
- The case originated from two Informations filed against Roxas and then Pasay City Mayor Wenceslao B. Trinidad (Trinidad), along with others.
- In SB-11-CRM-0249, it was alleged that Roxas and Trinidad unlawfully provided unwarranted benefits to IZUMO Contractors, Inc. by reconvening the Pre-Qualification Bids and Awards Committee (PBAC) despite its dissolution.
- In SB-11-CRM-0250, they were accused of conducting public bidding and awarding the contract for the Pasay City Mall and Public Market despite the establishment of a new Bids and Awards Committee (BAC).
Trial Proceedings
- Roxas and Trinidad pleaded not guilty upon arraignment, while their co-accused, Joselito A. Manabat and Alexander E. Ramos, remained at large.
- Four witnesses testified for the prosecution, inc