G.R. No. 235480 , January 27, 2021
Mario L. Relampagos, Rosario Salamida Nuñez, Lalaine Narag Paule and Marilou Dialino Bare, Petitioners, vs. Sandiganbayan (Second Division) and People of the Philippines, Respondents.

FACTS

This is a Joint Petition under Rule 65 seeking to annul the Sandiganbayan Resolution dated September 18, 2017, which found probable cause to issue warrants of arrest against the petitioners. The cases stem from the Priority Development Assistance Fund (PDAF) or “Pork Barrel” scam. Petitioners Mario L. Relampagos (then DBM Undersecretary), Rosario S. Nuñez, Lalaine N. Paule, and Marilou D. Bare (DBM staff) were indicted by the Ombudsman for violations of Section 3(e) of R.A. 3019 (Anti-Graft) and Malversation under the Revised Penal Code. The Ombudsman found that the PDAF scam was consummated through a modus operandi involving legislators, Janet Lim Napoles, and her NGOs. Petitioners were accused of facilitating with “undue haste” the processing of the Special Allotment Release Orders (SAROs) and Notice of Cash Allocations (NCAs) pertaining to the PDAF allocation of former Congressman Douglas Cagas, which were necessary for the release of funds to Napoles’ NGOs. After the Sandiganbayan issued warrants of arrest, petitioners filed a Joint Omnibus Motion for dismissal, which was denied. They then filed this petition, arguing the Sandiganbayan gravely abused its discretion in finding probable cause.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion, amounting to lack or excess of jurisdiction, in finding probable cause for the issuance of warrants of arrest against the petitioners.

RULING

The Supreme Court DISMISSED the petition and AFFIRMED the Sandiganbayan Resolution. The Court held that the Sandiganbayan did not commit grave abuse of discretion. The factual and legal issues raised by petitioners—such as their specific roles in preparing SAROs and NCAs, the ministerial nature of Relampagos’s signature, the timeline of SARO release, the lack of specific allegations in the Informations, and the absence of conspiracy—are evidentiary matters and matters of defense that should be passed upon after a full-blown trial on the merits. The Court found that petitioners were able to intelligently address all charges against them in their pleadings, indicating the Informations were not vague. There was no evidence that the Sandiganbayan acted arbitrarily or capriciously. Thus, its finding of probable cause prevails over petitioners’ allegations.