G.R. No. 233437 , April 26, 2021
People of the Philippines, Petitioner, vs. Honorable Sandiganbayan (Fourth Division), and Lauro L. Baja, Respondents.

FACTS

Lauro L. Baja, Jr., the Philippine Permanent Representative to the United Nations from 2003 to 2007, claimed and received reimbursements for representation expenses incurred in 2003, 2004, and 2005. A Commission on Audit (COA) audit and a subsequent Department of Foreign Affairs (DFA) fact-finding team found that these expenses, totaling US$28,934.96, were not properly documented. The audit observed that the submitted computerized receipts were not pre-numbered, lacked establishment names, and the check photocopies did not show receipt by payees. The fact-finding team’s investigation, which included an interview with a restaurant manager, raised questions about the authenticity and unusually high amounts of some expenses. An Information was filed accusing Baja of violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) by claiming reimbursements for “non-existent or fictitious” expenses through manifest partiality, evident bad faith, or gross inexcusable negligence, causing undue injury to the government. After the prosecution presented its evidence, Baja filed a Demurrer to Evidence. The Sandiganbayan granted the demurrer and dismissed the case, ruling that the prosecution failed to prove the expenses were non-existent or fictitious and failed to establish the elements of evident bad faith or gross negligence required for a violation of Section 3(e) of R.A. No. 3019 . The People of the Philippines filed a Petition for Certiorari assailing the Sandiganbayan’s Resolutions.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in granting the Demurrer to Evidence and dismissing the criminal case against Lauro L. Baja, Jr.

RULING

The Supreme Court dismissed the Petition for Certiorari. The Court held that the Sandiganbayan did not commit grave abuse of discretion. A demurrer to evidence grants the judge the authority to determine whether the prosecution’s evidence is sufficient to sustain a conviction. The Sandiganbayan’s evaluation of the evidence—finding that the prosecution failed to prove the expenses were non-existent or fictitious and failed to establish bad faith or gross negligence—was a valid exercise of its judicial discretion. The grant of the demurrer amounted to an acquittal. Any further prosecution for the same offense would violate the constitutional right against double jeopardy. The Court emphasized that a petition for certiorari cannot be used to reverse a judgment of acquittal, as an acquittal is final and unappealable.