Case Summary (G.R. No. 211703)
Petitioner
Edelbert C. Uyboco, tried and convicted by the Sandiganbayan for violation of Section 3(e), Republic Act No. 3019, as alleged co-conspirator of Governor Valencia.
Respondent
People of the Philippines, represented by the Office of the Special Prosecutor.
Key Dates
– March 1993: Issuance of Purchase Order No. 4979 and pro forma invoice for dump trucks.
– January 9, 2014: Sandiganbayan Decision convicting Uyboco and Valencia.
– March 14, 2014: Sandiganbayan Resolution denying motion to reconsider and to reopen proceedings.
– December 10, 2014: Supreme Court Resolution affirming the conviction.
Applicable Law
– 1987 Philippine Constitution (due process guarantee).
– Republic Act No. 3019 § 3(e) (Anti-Graft and Corrupt Practices Act).
– Rule 45 of the Rules of Court (petition for review on certiorari).
– Local Government Code §§ 356, 369 (public procurement).
Procedural History
Uyboco petitioned for review under Rule 45, challenging the Sandiganbayan’s factual findings of conspiracy and the denial of his motion to reopen on grounds of counsel incompetence and due-process violation. The Office of the Special Prosecutor opposed, invoking the principle that a client is bound by counsel’s actions.
Issues on Appeal
- Whether the Sandiganbayan erred in finding a conspiracy between Uyboco and Valencia absent proof beyond reasonable doubt.
- Whether Uyboco’s constitutional right to due process and to competent counsel was violated when his former lawyer allegedly failed to present evidence.
Standard of Review
Under Rule 45, only questions of law are reviewable. Factual findings of the Sandiganbayan, affirmed by the appellate court, bind the Supreme Court unless there is a clear showing of grave abuse of discretion, misapprehension of facts, or conclusions based on speculation.
Conspiracy and Liability under RA 3019 § 3(e)
– Private persons may be charged in conspiracy with public officers (People v. Henry T. Go).
– Sandiganbayan found that Uyboco and Valencia collaborated in awarding an overpriced contract for dump trucks, as evidenced by their joint execution of the purchase order and pro forma invoice.
– Uyboco did not dispute the documentary proof of their joint participation.
Violation of Procurement Rules
– Valencia, without Sangguniang Panlalawigan authorization, approved the negotiated purchase of dump trucks prior to any failed biddings, in breach of Local Government Code § 369.
– Alleged “failed biddings” were shown to be simulated.
– Analogous to Plameras v. People, wherein sidestepping procurement rules constituted gross inexcusable negligence.
Undue Injury and Unwarranted Benefit
– Direct importation entitled the Provincial Government to a tax-free price of PHP 4,594,119.85.
– Disbursement reached PHP 6,994,286.00, resulting in an overpayment of PHP 2,400,166.15 to Gaikoku.
– This constituted undue injury to the Government and an unwarranted benefit to the private party, satisfying the third element of § 3(e).
Due Process and Competent Counsel
– Uyboco alleged his former counsel refused to present evidence, failed to cross-examine the main witness, and omitted filing a defense memorandum, thus violating his right to due process under the 1987 Constitution.
– The Sandiganbayan found that Uyboco expressly waived his right to present evidence by signing a formal manifestation, and that a belated memorandum was admitted in the interest of justice.
Exc
Case Syllabus (G.R. No. 211703)
Facts
- Petitioner Edelbert C. Uyboco was charged with co-accused Rodolfo G. Valencia under Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) in Sandiganbayan Criminal Case No. 24461.
- The charge stemmed from the negotiated procurement of dump trucks by the Provincial Government at an allegedly inflated price of ₱6,994,286.00, causing an excess payment of ₱2,400,166.15.
- Valencia, a public officer, approved the purchase without prior Sangguniang Panlalawigan resolution and without two failed public biddings as required by Section 369 of the Local Government Code.
- Uyboco, president of Gaikoku, the supplier, was alleged to have conspired with Valencia to secure undue benefits.
Petitioner’s Motion to Reopen Proceedings
- Petitioner moved to reopen proceedings, citing denial of due process and incompetent counsel performance.
- He claimed his former counsel:
- Advised that no preliminary investigation or evidence presentation was necessary.
- Failed to cross-examine the main prosecution witness due to absence at trial.
- Did not prepare or file a memorandum timely, merely adopting co-accused defenses.
- Petitioner argued these errors caused serious prejudice to his defense.
Procedural History
- Sandiganbayan issued a Decision (January 9, 2014) finding petitioner and Valencia guilty beyond reasonable doubt.
- A Resolution (March 14, 2014) denied Uyboco’s Motion for Reconsideration and Plea to Reopen Proceedings.
- Petitioner filed a Petition for Review on Certiorari (G.R. No. 211703) before the Supreme Court, raising questions of law only.
Issue
- Whether the Sandiganbayan erred in:
- Finding the existence of a conspiracy between Uyboco and Valencia.
- Convicting petitioner without proof beyond reasonable doubt of conspiracy.
- Denying petitioner’s motion to reopen proceedings on grounds