G.R. No. 220598 & G.R. No. 220953, July 19, 2016
Gloria Macapagal-Arroyo and Benigno B. Aguas, Petitioners, vs. People of the Philippines and the Sandiganbayan (First Division), Respondents.

FACTS

Petitioners Gloria Macapagal-Arroyo (GMA), former President, and Benigno Aguas, former PCSO Budget Officer, were charged with Plunder before the Sandiganbayan. The Information alleged that from 2008 to 2010, they conspired with other PCSO and COA officials to amass P365,997,915.00 by diverting PCSO operating funds to its Confidential/Intelligence Fund (CIF) and raiding the public treasury through irregular disbursements for personal gain. After the prosecution rested its case, GMA and Aguas filed demurrers to evidence, arguing the evidence failed to prove their guilt beyond reasonable doubt, particularly the elements of plunder, including conspiracy and personal benefit.
The Sandiganbayan denied the demurrers. It found the prosecution evidence, primarily the testimonial and documentary proofs presented, sufficient to warrant a trial on the merits. The anti-graft court held that the evidence, if unrebutted, could sustain a conviction, noting the alleged irregularities in the CIF disbursements and the purported conspiracy among the accused. Their motions for reconsideration were likewise denied. Aggrieved, GMA and Aguas filed these consolidated petitions for certiorari, alleging the Sandiganbayan committed grave abuse of discretion in denying their demurrers.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the petitioners’ demurrers to evidence.

RULING

No, the Sandiganbayan did not commit grave abuse of discretion. A demurrer to evidence tests the sufficiency of the prosecution’s evidence to sustain a conviction. In resolving it, the court must determine whether the evidence, prima facie, establishes the accused’s guilt. The court does not weigh the evidence’s credibility or conclusively determine innocence or guilt at this stage. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction.
The Supreme Court, reviewing the Sandiganbayan’s resolutions, found no such arbitrariness. The prosecution presented evidence, including testimonies and documents detailing the processes for CIF releases and alleged irregularities. For plunder under R.A. 7080, the prosecution must allege and eventually prove a conspiracy to amass ill-gotten wealth exceeding P50 million through a series of overt acts. The Sandiganbayan, in its assailed resolutions, meticulously summarized the prosecution’s evidence, linking the petitioners to the alleged scheme. It found prima facie evidence suggesting GMA’s approval of fund increases and Aguas’ involvement in fund processing and liquidation. The Court held that whether this evidence conclusively proves conspiracy and personal benefit is a matter for full trial. Denying the demurrer was a proper exercise of judicial discretion to allow the trial to proceed and for the accused to present their defense. The petitions were dismissed for lack of merit.