G.R. Nos. 164068-69, 166305-06, 166487-88. November 19, 2013.
ROLANDO P. DE LA CUESTA, Petitioner, vs. THE SANDIGANBAYAN, FIRST DIVISION and THE PEOPLE OF THE PHILIPPINES, Respondents. PEOPLE OF THE PHILIPPINES, Petitioner, vs. EDUARDO M. COJUANGCO JR., et al., Respondents. REPUBLIC OF THE PHILIPPINES, Petitioner, vs. THE SANDIGANBAYAN, et al., Respondents.

FACTS

The Office of the Ombudsman filed two Informations before the Sandiganbayan against former members of the Philippine Coconut Authority (PCA) Governing Board, including Rolando P. De La Cuesta and Eduardo Cojuangco Jr. They were charged with violating Section 3(e) of R.A. 3019 (Anti-Graft Law) for granting financial assistance of ₱2 million in 1984 and ₱6 million in 1985 to the Philippine Coconut Producers Federation (COCOFED), a private entity. The prosecution alleged the grants were made with evident bad faith and manifest partiality, causing undue injury to the government. The Sandiganbayan initially granted the accused’s motions for leave to file a motion for reconsideration with the Ombudsman.
Subsequently, the Ombudsman, through a Memorandum, recommended the dismissal of the cases. The accused then filed motions to dismiss. The Office of the Solicitor General (OSG), opposing the dismissal, presented key documents to the Sandiganbayan, including PCA Board memoranda and minutes justifying the grants. The OSG argued the grants were for legitimate coconut industry programs. The Sandiganbayan, however, granted the motions to dismiss and withdrew the Informations, finding no probable cause. The OSG and the Republic filed petitions for certiorari before the Supreme Court, arguing the Sandiganbayan gravely abused its discretion.

ISSUE

Did the Sandiganbayan commit grave abuse of discretion in dismissing the criminal cases and finding no probable cause against the accused for violation of Section 3(e) of R.A. 3019?

RULING

Yes, the Sandiganbayan committed grave abuse of discretion. The Supreme Court held that the Sandiganbayan’s finding of no probable cause was based on a misappreciation of facts and law. Probable cause merely requires a reasonable belief that a crime has been committed and the accused is probably guilty. The Court found that the prosecution’s evidence, including the PCA memoranda and board resolutions, sufficiently established probable cause for the elements of the crime.
The legal logic is that for a violation of Section 3(e) of R.A. 3019, the act of granting financial aid to a private entity, COCOFED, using public funds from a special fund (PCA Fund 503) not appropriated for such purpose, prima facie constitutes the elements of the offense: the accused are public officers; they acted with manifest partiality or evident bad faith; their action caused undue injury to the government or gave unwarranted benefit to a private party. The Sandiganbayan erred by delving into the merits of the justifications for the grants, which is a matter for full trial. By dismissing the cases at the probable cause stage based on its own assessment of the validity of the expenditures, it exceeded its discretion and effectively preempted a trial on the merits. The orders of dismissal were annulled and the cases were remanded for further proceedings.