G.R. No. 210488, December 1, 2021
JOSE MIGUEL T. ARROYO, PETITIONER, VS. THE HON. SANDIGANBAYAN – FIFTH DIVISION AND THE PEOPLE OF THE PHILIPPINES, RESPONDENTS.

FACTS

The Office of the Ombudsman investigated anomalies in the Philippine National Police’s 2009 purchase of light operational police helicopters. It found that two Robinson R44 Raven helicopters, pre-owned by petitioner Jose Miguel T. Arroyo, were sold to the PNP through Manila Aerospace Products Trading Corporation despite a requirement for brand-new units. Arroyo, along with others, was indicted for violating Section 3(e) of Republic Act No. 3019 for causing undue injury to the government. Arroyo pleaded not guilty during arraignment, a condition for obtaining travel authority. He filed a Motion for Judicial Determination of Probable Cause before the Sandiganbayan, arguing lack of evidence of his ownership of the helicopters and his participation in the sale or conspiracy. The Sandiganbayan denied his motion, finding probable cause based on the evidence. Arroyo’s Petition for Certiorari was dismissed by the Supreme Court, prompting this Motion for Reconsideration.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in affirming the Office of the Ombudsman’s finding of probable cause to indict Arroyo for violation of Section 3(e) of Republic Act No. 3019.

RULING

The dissenting opinion argues that the Court must not interfere with the Office of the Ombudsman’s exercise of prerogatives absent a clear showing of grave abuse of discretion. Allegations of misappreciation of evidence are insufficient to establish such abuse. The Sandiganbayan correctly found probable cause based on the evidence on record, which indicated Arroyo’s participation. The elements of the offense were present: the accused were public officers or private individuals charged in conspiracy with them; the acts were committed in relation to public positions; the transaction caused undue injury to the PNP and the government; it gave unwarranted benefits to Arroyo; and the accused acted with manifest partiality, evident bad faith, or gross inexcusable negligence. The Sandiganbayan followed the proper procedure in determining probable cause, and absent contrary evidence, it cannot overturn the Ombudsman’s findings. Arroyo’s arguments regarding ownership, based on challenging the credibility and weight of evidence like witness testimony and documents, pertain to the merits of the case best determined in a full-blown trial, not in a probable cause determination. His arraignment did not waive his right to question the finding of probable cause. The motion for reconsideration should be denied.