GR 141336; (June, 2004) (Digest)
G.R. No. 141336 ; June 29, 2004
RODOLFO G. VALENCIA, ET AL., petitioners, vs. SANDIGANBAYAN, 4TH DIVISION and OFFICE OF THE OMBUDSMAN/SPECIAL PROSECUTOR, respondents.
FACTS
Petitioners, provincial officials of Oriental Mindoro, were charged before the Sandiganbayan with violating Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act). The Information alleged they conspired to grant a P2.5 million loan from provincial funds to a private individual, Engr. Alfredo Atienza, to finance the repair and operation of his vessel, which contract was grossly disadvantageous to the government. After the filing of the Information, petitioners sought and were granted a reinvestigation. The Office of the Ombudsman, through a Joint Resolution, maintained the criminal charge against most petitioners, leading to the filing of an Amended Information.
Subsequently, petitioners discovered that in a separate administrative case (OMB-ADM-1-96-0316) involving the identical loan transaction, the Ombudsman had dismissed the complaint against them. The administrative dismissal found that the loan contract was entered pursuant to the local government’s police power under the General Welfare Clause. Invoking this resolution, petitioners filed with the Sandiganbayan a Motion for Reconsideration and/or a Motion to Quash the Information, arguing that the administrative dismissal should bar the criminal prosecution. The Sandiganbayan denied their motions in two separate Resolutions.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the Motion to Quash the Information despite the prior dismissal of the administrative case involving the same transaction.
RULING
The Supreme Court ruled that the Sandiganbayan did not commit grave abuse of discretion. The dismissal of the administrative case is not a ground for the dismissal of the criminal case. Administrative and criminal cases are distinct from each other. They require different standards of proof—substantial evidence for administrative liability and proof beyond reasonable doubt for criminal conviction. An administrative proceeding is not a prerequisite to a criminal prosecution, nor does its outcome determine the guilt or innocence in a criminal case. The Ombudsman’s finding in the administrative case that the act was pursuant to the General Welfare Clause does not automatically absolve petitioners from criminal liability, as the elements of the crime under R.A. No. 3019 must still be proven in a full-blown trial. A Motion to Quash an Information is limited to the grounds provided under Rule 117 of the Rules of Court, and the alleged prior administrative dismissal is not among these statutory grounds. The Sandiganbayan correctly proceeded to trial to determine criminal liability based on the evidence presented.