G.R. No. 171513 & G.R. No. 190963; February 6, 2012
ARNOLD JAMES M. YSIDORO, Petitioner, vs. HON. TERESITA J. LEONARDO-DE CASTRO, et al., and NIERNA S. DOLLER, Respondents. / PEOPLE OF THE PHILIPPINES, Petitioner, vs. FIRST DIVISION OF THE SANDIGANBAYAN and ARNOLD JAMES M. YSIDORO, Respondents.

FACTS

Arnold James M. Ysidoro, the Municipal Mayor of Leyte, Leyte, was charged before the Sandiganbayan with violation of Section 3(e) of R.A. No. 3019 . The Information alleged that from June to December 2001, with manifest partiality and evident bad faith, he unlawfully withheld the Representation and Transportation Allowance (RATA) and Productivity Pay of Municipal Social Welfare Officer Nierna S. Doller. The prosecution, during trial, presented Doller as its sole witness, who testified that the withholding was politically motivated after her husband sided with Ysidoro’s opponent.
The Sandiganbayan, upon the prosecution’s motion, issued a Resolution ordering Ysidoro’s preventive suspension for 90 days pursuant to the mandatory provision of Section 13 of R.A. No. 3019 . Ysidoro challenged this suspension via a petition for certiorari ( G.R. No. 171513 ). Meanwhile, trial proceeded. The defense presented several witnesses and evidence to show that the withholding was due to an ongoing investigation into anomalies allegedly committed by Doller, which prompted Ysidoro to order the padlocking of her office and restrict her travel.

ISSUE

The consolidated petitions raised two primary issues: (1) In G.R. No. 171513 , whether the Sandiganbayan committed grave abuse of discretion in ordering Ysidoro’s preventive suspension; and (2) In G.R. No. 190963, whether the Sandiganbayan committed grave abuse of discretion in acquitting Ysidoro of the graft charge.

RULING

The Supreme Court dismissed both petitions. Regarding the preventive suspension ( G.R. No. 171513 ), the petition was rendered moot and academic because the suspension period had long expired and the main criminal case had already been terminated by Ysidoro’s acquittal. An action is moot when it no longer presents a justiciable controversy.
Regarding the acquittal (G.R. No. 190963), the Court found no grave abuse of discretion by the Sandiganbayan. The Court emphasized that a petition for certiorari under Rule 65 assailing an acquittal is an extraordinary remedy, permissible only upon a clear showing that the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction. The Sandiganbayan, in its decision, found that the prosecution failed to prove the element of “manifest partiality, evident bad faith, or gross inexcusable negligence” required under Section 3(e) of R.A. No. 3019 . It held that Ysidoro’s act of withholding Doller’s benefits was due to a legitimate administrative investigation, not ill will or bad faith. The Supreme Court ruled that the Sandiganbayan’s assessment of the evidence and its conclusion on the absence of criminal intent involved an evaluation of facts and credibility, which is within its exclusive domain. Absent any capricious, whimsical, or arbitrary exercise of judgment, its acquittal decision must stand. The Court cannot substitute its own judgment for that of the Sandiganbayan on factual matters.