G.R. No. 185503 , 187603, 192166 May 03, 2021
People of the Philippines, Petitioner, vs. Honorable Sandiganbayan (Second Division) and Thadeo Z. Ouano, Respondents. / People of the Philippines, Petitioner, vs. Honorable Sandiganbayan (Second Division) and Isabelo A. Braza, Respondents. / People of the Philippines, Petitioner, vs. Honorable Sandiganbayan (Second Division) and Robert F. Lala, Gloria R. Dindin, Marlina S. Alvizo, Pureza A. Fernandez, Agustino P. Hermoso, Luis A. Galang, Cresencio T. Bagolor, Buenaventura C. Pajo, and Restituto R. Diano, Respondents.

FACTS

A fact-finding investigation was initiated regarding streetlamps installed for the 12th ASEAN Summit in Cebu. The Office of the Ombudsman-Visayas conducted a preliminary investigation. Respondents Lala, et al. filed motions claiming they were not furnished complete copies of the Final Evaluation Report, hindering their ability to file counter-affidavits. The Court of Appeals set aside the Ombudsman’s order denying their request for the missing pages. Despite this, an Information was filed with the Sandiganbayan on April 22, 2008, charging respondents with violation of Republic Act No. 3019 for entering into a contract grossly disadvantageous to the government. Respondents filed various motions before the Sandiganbayan, including motions to dismiss, for reinvestigation, and to resolve pending motions for reconsideration filed with the Ombudsman. The Ombudsman, through a Special Prosecutor, filed a Motion to Withdraw Information, stating a re-evaluation showed the evidence was insufficient to establish probable cause. The Sandiganbayan granted the motion and dismissed the criminal case. The People of the Philippines, through the Office of the Special Prosecutor, filed petitions for certiorari challenging the dismissal.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in granting the Ombudsman’s Motion to Withdraw Information and dismissing the criminal case.

RULING

No. The Sandiganbayan did not commit grave abuse of discretion. Once an information is filed in court, the court acquires jurisdiction over the case, and any disposition, including its dismissal, rests on the court’s sound discretion. The court is not bound by the prosecutor’s or the Ombudsman’s desire to dismiss the case. The Sandiganbayan independently assessed the merits of the Motion to Withdraw Information. It noted the Ombudsman’s finding of insufficient evidence and the pendency of unresolved motions for reconsideration. The Sandiganbayan’s dismissal was based on its own determination that the withdrawal of the information was justified. The court acted within its jurisdiction and did not act in a capricious, whimsical, or arbitrary manner. The petitions were dismissed.