GR 167048; (April, 2006) (Digest)
G.R. No. 167048 ; April 7, 2006
MARIETTA T. CAUGMA, AMIANA ABELLA and ROSAURO MARTINEZ, Petitioners, vs. THE PEOPLE OF THE PHILIPPINES and the SANDIGANBAYAN, Respondents.
FACTS
Petitioners were members of the Bureau of Fisheries and Aquatic Resources (BFAR) Disposal Committee tasked with selling the unserviceable vessel M/V Malasugui via public bidding under Executive Order No. 888. The Committee appraised the vessel at P86,917.60 and set this as the minimum bid price. During the public auction, only one bidder, Atty. Rogelio A. Garcia, participated and submitted a bid of P86,918.00, which was merely P0.40 above the floor price. The Committee, despite this single bid, proceeded to award the vessel to Garcia. The Sandiganbayan convicted petitioners of violating Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) for giving Garcia unwarranted benefit and causing undue injury to the government through manifest partiality and evident bad faith in the conduct of the bidding.
ISSUE
Whether petitioners are guilty beyond reasonable doubt of violating Section 3(e) of R.A. No. 3019.
RULING
The Supreme Court acquitted petitioners. The prosecution failed to prove the elements of the crime with moral certainty. For a violation of Section 3(e), the act must be attended by manifest partiality, evident bad faith, or gross inexcusable negligence. The Court found no evidence of these modalities. The Committee complied with the prescribed procedure: it publicly advertised the sale, conducted the bidding, and accepted the sole bid which exceeded the appraised value. The law or executive order did not require a specific number of bidders, nor did it mandate the failure of the bidding if only one bid was received. The mere fact that only one bidder participated does not, by itself, establish manifest partiality or bad faith. The prosecution did not present proof that petitioners manipulated the process to ensure only Garcia would bid or that they had any illicit motive. Absent such evidence, the element of criminal intent is lacking. The Court emphasized that in criminal cases, the burden is on the prosecution to prove guilt beyond reasonable doubt, and mere suspicion or conjecture is insufficient to sustain a conviction.