GR 140183; (July, 2003) (Digest)
G.R. No. 140183 ; July 10, 2003
TEODORO K. KATIGBAK and BIENVENIDO E. MERELOS, petitioners, vs. THE SANDIGANBAYAN and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioners Teodoro K. Katigbak and Bienvenido E. Merelos, along with other National Housing Authority (NHA) officials, were charged before the Sandiganbayan with violating Section 3(e) of R.A. 3019 (Anti-Graft Law). The amended information alleged that they, through evident bad faith and manifest partiality, conspired to unilaterally rescind NHA’s infrastructure contract with Arceo Cruz of A.C. Cruz Construction for the Pahanocoy Sites and Services Project in Bacolod City. They were accused of subsequently awarding the contract for the remaining work to Jose Cruz of Triad Construction and Development Corporation without public bidding and at an exorbitant price of over P10 million, compared to an estimated cost of about P4.9 million, causing undue injury to the government and the original contractor.
After the prosecution rested its case, the petitioners filed a demurrer to evidence, arguing that the prosecution failed to prove their guilt beyond reasonable doubt. The Sandiganbayan denied the demurrer in a Resolution dated April 7, 1999, and also denied their motion for reconsideration. The petitioners then filed this petition for certiorari and prohibition under Rule 65, seeking to annul the Sandiganbayan’s resolutions for having been issued with grave abuse of discretion.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the petitioners’ demurrer to evidence.
RULING
Yes. The Supreme Court granted the petition, reversing the Sandiganbayan’s resolutions. The Court held that the prosecution’s evidence was insufficient to prove the essential elements of the crime, particularly the existence of evident bad faith or manifest partiality. A demurrer to evidence should be granted when the prosecution’s evidence is insufficient to support a conviction. The Court found that the rescission of the original contract was justified due to the contractor’s failure to meet the required work accomplishment rate, a fact established by prosecution witness Felicisimo Lazarte, Jr. Furthermore, the award to Triad Construction was shown to be a negotiated contract, permissible under existing rules for the continuation of an ongoing project, and the price difference was attributable to necessary price adjustments and additional work not included in the original contract. The prosecution failed to present any evidence that the petitioners acted with a malicious intent or a conscious and deliberate design to do wrong, which is required to establish evident bad faith. Since the evidence did not prove the petitioners’ guilt beyond reasonable doubt, the Sandiganbayan’s denial of the demurrer constituted grave abuse of discretion. The Court emphasized that the State must always prove the guilt of an accused beyond reasonable doubt, and the accused must be shielded from useless and expensive litigations.