G.R. No. 219824-25, February 12, 2019
PEOPLE OF THE PHILIPPINES, Petitioner vs. HONORABLE SANDIGANBAYAN (First Division), MARIO L. RELAMPAGOS, MARILOU D. BARE, ROSARIO S. NUNEZ and LALAINE N. PAULE, Respondents

FACTS

This case arose from the Priority Development Assistance Fund (PDAF) scam. Following whistleblower Benhur Luy’s disclosures, the National Bureau of Investigation and the Ombudsman’s Field Investigation Office filed complaints against several public officials, including respondents Mario L. Relampagos (then DBM Undersecretary) and his subordinates Marilou D. Bare, Rosario S. Nunez, and Lalaine N. Paule. They were accused of conspiring with former Congressman Constantino Jaraula and Janet Lim Napoles to misappropriate P30 million from Jaraula’s PDAF allocation in 2007. The funds were allegedly channeled through the Technology Resource Center to a Napoles-controlled NGO.
The Ombudsman found probable cause to indict respondents for three counts each of violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) and malversation of public funds. The Ombudsman held that respondents, who processed the pertinent Special Allotment Release Orders (SAROs) and Notices of Cash Allocation (NCAs), exhibited manifest partiality by expediting these documents for Napoles. However, upon filing the Informations, the Sandiganbayan dismissed the cases against respondents for lack of probable cause, ruling that the Ombudsman’s evidence failed to establish their conspiracy with Jaraula and Napoles or any overt criminal act.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing the criminal cases against respondents for lack of probable cause.

RULING

Yes, the Sandiganbayan committed grave abuse of discretion. The Supreme Court clarified that a judge’s duty to determine probable cause is not an exercise of an appellate review over the prosecutor’s finding. The judge does not examine the evidence to determine guilt beyond reasonable doubt, but only whether there is sufficient ground to engender a well-founded belief that a crime was committed and the accused is probably guilty. The Sandiganbayan overstepped this limited judicial function by weighing the evidence as if it were already conducting a trial on the merits.
The Court found that the Ombudsman presented sufficient evidence to establish probable cause against respondents. This included whistleblower Benhur Luy’s positive identification of respondents as Napoles’s “contact persons” within the DBM, the Commission on Audit Report highlighting irregularities in the issuance of the SAROs and NCAs, and the fact that the questioned documents were indeed issued from respondents’ office. These circumstances collectively indicated respondents’ possible manifest partiality and bad faith, causing undue injury to the government. Therefore, the Sandiganbayan’s dismissal, which effectively precluded a full trial, was a capricious and whimsical exercise of judgment constituting grave abuse of discretion. The Court reinstated the criminal Informations and ordered the Sandiganbayan to proceed with the trial.