GR 176819; (January, 2011) (Digest)
G.R. No. 176819 ; January 26, 2011
PEOPLE OF THE PHILIPPINES, Petitioner, vs. ROBERT P. BALAO, JOSEPHINE C. ANGSICO, VIRGILIO V. DACALOS, and SANDIGANBAYAN, First Division, Respondents.
FACTS
On May 1, 2001, an Information dated March 5, 2001, was filed with the Sandiganbayan charging respondents Robert P. Balao, Josephine C. Angsico, Virgilio V. Dacalos, and others with violation of Section 3(e) of R.A. No. 3019 . The Information alleged that in March 1992, the accused public officials, in connivance with a private individual, caused the payment of public funds amounting to P232,628.35 to A.C. Construction for excavation and roadfilling works on the Pahanocoy Sites and Services Project in Bacolod City, despite no such works having been undertaken, thereby giving unwarranted benefits to the contractor to the damage of the government. On May 22, 2001, the Sandiganbayan found the Information inadequate as it did not clearly state the participation of each accused. The prosecution was directed to clarify but subsequently recommended maintaining the Information. Respondents Balao, Angsico, and Dacalos moved for reinvestigation, which was granted by the Sandiganbayan on March 27, 2005, noting the prosecution’s failure to address the inadequacy. After reinvestigation, the prosecution again recommended maintaining the Information. Respondents then filed motions to quash the Information.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in granting the motions to quash the Information filed by respondents Balao, Angsico, and Dacalos on the ground that the Information failed to state their acts or omissions with sufficient particularity.
RULING
Yes. The Supreme Court granted the petition, set aside the Sandiganbayan’s Resolution, and ordered the reinstatement of respondents as accused. The Court held that the Information sufficiently alleged the ultimate facts constituting the offense of violation of Section 3(e) of R.A. No. 3019 . It stated the names of the accused, their official positions, the time and place of the commission of the offense, the amount involved, the alleged acts performed in conspiracy (causing payment for works not undertaken), and the resulting damage. The Court ruled that an Information only needs to state the ultimate facts, not the evidentiary details. The participation of each accused in a conspiracy need not be described in detail in the Information; the specific acts of individual conspirators are matters of evidence to be presented during trial. The Sandiganbayan’s requirement for a more detailed description of individual acts exceeded the standards for a valid Information and constituted grave abuse of discretion.