GR 138792 804; (March, 2005) (Digest)
G.R. Nos. 138792-804. March 31, 2005. DANTE GUEVARRA, AUGUSTUS F. CESAR and ADRIANO SALVADOR, Petitioners, vs. THE HON. FOURTH DIVISION OF THE SANDIGANBAYAN, PEOPLE OF THE PHILIPPINES, ZENAIDA P. PIA and CRESENCIANO D. GATCHALIAN, Respondents.
FACTS
Petitioners Dante Guevarra, Augustus Cesar, and Adriano Salvador, along with Dr. Zenaida Olonan, were administrators of the Polytechnic University of the Philippines (PUP). They were charged before the Sandiganbayan with multiple counts of violating Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) in connection with various allegedly anomalous transactions. Initially, a single Information (Criminal Case No. 22854) was filed. Upon motion of the Special Prosecutor, this case was withdrawn and dismissed, and 17 separate Informations were subsequently filed. The Ombudsman later approved a review recommendation to drop some charges against Olonan but to retain her and the other petitioners as accused in several cases.
The procedural confusion arose when the Special Prosecutor, in a Manifestation and Motion before the Sandiganbayan, cited the review recommendation and moved for the dismissal of 13 specific criminal cases. The Sandiganbayan granted this motion and dismissed the 13 cases. However, the Special Prosecutor later filed a Motion for Reconsideration, clarifying that the Ombudsman’s approval for dismissal pertained only to accused Olonan, not to petitioners Guevarra, Cesar, and Salvador. The Sandiganbayan granted the reconsideration and reinstated the 13 cases against the petitioners.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in granting the prosecution’s motion for reconsideration and reinstating the criminal cases against the petitioners.
RULING
The Supreme Court ruled that the Sandiganbayan did not commit grave abuse of discretion. The Court emphasized that the Sandiganbayan’s initial order dismissing the 13 cases was based on a mistaken factual premise—that the Ombudsman had approved the dismissal of all charges against all accused, including the petitioners. The Special Prosecutor’s subsequent motion for reconsideration correctly clarified that the approved dismissal applied only to co-accused Olonan. The Sandiganbayan, in rectifying its earlier void order, acted in accordance with law and its inherent power to correct errors to promote substantial justice.
The legal logic is anchored on the principle that the State is equally entitled to due process. A court can reconsider and set aside an order issued under a misapprehension of facts. The Sandiganbayan’s act of reinstatement was a proper exercise of judicial discretion to correct a manifest error, not a capricious or whimsical act constituting grave abuse of discretion. The petitioners’ right against double jeopardy was not violated because the dismissal of the cases was based on a procedural mistake, not an acquittal on the merits or a termination without their express consent. The petition for certiorari was therefore dismissed.