G.R. No. 144159 ; September 29, 2004
PEOPLE OF THE PHILIPPINES, petitioner, vs. SANDIGANBAYAN and MANUEL S. ALBA, respondents.

FACTS

The case originated from a complaint filed against Manuel S. Alba, the City Administrator of Quezon City, for allegedly violating Section 3(e) of R.A. 3019. The complaint alleged that Alba, with evident bad faith and manifest partiality, issued a memorandum recalling a final and executory demolition order against a church structure (IEMELIF) that had encroached on private land and was built without a permit. The Information highlighted that the recall memorandum was dated November 4, 1998, which was a day before the church’s appeal letter was received by his office on November 5, 1998, suggesting a premature and unauthorized act.
Alba moved to quash the Information, arguing the finding of probable cause was unsupported. The Sandiganbayan granted a reinvestigation. The Ombudsman, upon reinvestigation, affirmed the finding of probable cause. However, the Sandiganbayan, in its assailed Resolution, quashed the Information and acquitted Alba. It ruled that Alba acted within his delegated authority from the Mayor to recall demolitions pending appeal, and that the date discrepancy on the memorandum was a mere clerical error. The prosecution filed this petition for certiorari.

ISSUE

Whether the Sandiganbayan acted with grave abuse of discretion amounting to lack or excess of jurisdiction in quashing the Information and acquitting the accused.

RULING

Yes. The Supreme Court granted the petition, nullified the Sandiganbayan’s Resolution, and ordered the remand of the case for further proceedings. The Court held that the Sandiganbayan committed grave abuse of discretion by pre-emptively evaluating the evidence and making a definitive ruling on the merits during what should have been a preliminary determination on the sufficiency of the Information. The Information validly alleged the elements of the offense under Section 3(e) of R.A. 3019: that Alba was a public officer who, in the performance of his functions, through manifest partiality or evident bad faith, caused undue injury or gave unwarranted benefits. The question of whether Alba’s act was justified by a delegated authority or whether the date was a clerical error are matters of defense that require a full trial on the merits for proper adjudication. By dismissing the case at that stage, the Sandiganbayan deprived the prosecution of its right to due process and to present evidence to prove the allegations in court. Consequently, the acquittal was void and did not constitute a proper basis for a claim of double jeopardy.