GR 139618; (July, 2006) (Digest)
G.R. No. 139618 ; July 11, 2006
STEVENS N. FUENTES, petitioner, vs. THE SANDIGANBAYAN and THE PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Stevens N. Fuentes, as Municipal Mayor of Banga, Aklan, entered into a Deed of Sale for a parcel of land on behalf of the municipality. The Sangguniang Bayan later failed to pass a resolution authorizing the purchase. Consequently, the seller returned the payment, and petitioner executed an Affidavit of Rescission. A complaint was filed against him for violating Section 3(g) of R.A. No. 3019 , alleging the purchase was grossly disadvantageous to the government. The Office of the Ombudsman (Visayas) initially recommended dismissal, but then Ombudsman Aniano Desierto disapproved it, opining the offense was consummated upon the signing of the contract. An Information was subsequently filed with the Sandiganbayan.
After reinvestigation, the Office of the Special Prosecutor, having found that not all elements of the offense were present, filed a Motion to Withdraw Information for insufficiency of evidence. Petitioner also filed a Motion to Quash. The Sandiganbayan denied both motions, ruling that the determination of evidentiary sufficiency is best addressed to the court after trial and that the facts in the Information prima facie constituted an offense.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the Motion to Quash and the prosecution’s Motion to Withdraw Information.
RULING
Yes. The Supreme Court granted the petition, setting aside the Sandiganbayan’s resolutions. The Court emphasized that while the court acquires jurisdiction over a case upon the filing of the Information and is not bound by the prosecution’s recommendations, it must exercise judicial discretion by conducting a judicious evaluation of the prosecution’s evidence when ruling on a motion to withdraw an information. The Sandiganbayan gravely abused its discretion by merely relying on the arguments of the private complainant and the Ombudsman’s initial marginal note, without independently evaluating the evidence that led the prosecution to conclude the evidence was insufficient. By failing to perform this duty, the Sandiganbayan relinquished its discretion. The Court found that the Sandiganbayan’s resolutions contained no evaluation of the prosecution’s evidence to justify denying the withdrawal, thereby acting arbitrarily.