Relampagos v. Sandiganbayan
REITERATIONFacts
The Antecedents: The case involves the Priority Development Assistance Fund (PDAF) scam, also known as the Pork Barrel Scam. Following the rescue of Benhur Luy from Janet Lim Napoles, Luy executed an affidavit detailing Napoles' involvement in facilitating government projects funded by PDAF. The Office of the Ombudsman (Ombudsman) conducted a fact-finding investigation, considering reports from the Commission on Audit (COA). Procedural History: The Ombudsman found probable cause against petitioners Mario L. Relampagos, Rosario Salamida Nuñez, Lalaine Narag Paule, and Marilou Dialino Bare (collectively, petitioners) for violations of Section 3(e) of Republic Act No. 3019 (Anti-graft and Corrupt Practices Act) and Article 217 of the Revised Penal Code (Malversation). The Sandiganbayan, Second Division, issued warrants of arrest against them. Petitioners filed a Joint Omnibus Motion seeking dismissal, to hold warrants in abeyance, and for a bill of particulars. The Sandiganbayan treated this as a motion for reconsideration and denied it in a Resolution dated September 18, 2017, finding probable cause and stating that factual and legal issues should be resolved after trial. The Petition: Petitioners filed a Joint Petition for Certiorari under Rule 65 of the Rules of Court, assailing the Sandiganbayan's Resolution for grave abuse of discretion, arguing lack of probable cause, that SAROs and NCAs are prepared by the DBM and not by them, that Relampagos only signed SAROs ministerially, and that there was no evidence against Nuñez, Paule, and Bare. They also argued they were not accountable officers for malversation and that conspiracy could not be inferred.
Issue(s)
Whether the Sandiganbayan gravely abused its discretion, amounting to lack or excess of jurisdiction, in finding probable cause against the petitioners. Whether the Sandiganbayan erred in denying petitioners' Joint Omnibus Motion for dismissal, to hold warrants in abeyance, and for a bill of particulars.
Ruling
The Supreme Court found no merit in the petition and dismissed it. The Resolution dated September 18, 2017, issued by the Sandiganbayan, Second Division, was affirmed.
Ratio Decidendi
On the Propriety of Petitioners' Motion for Determination of Probable Cause: The Court reiterated the distinction between the executive determination of probable cause by the prosecutor and the judicial determination by the judge for the issuance of a warrant of arrest. It held that once the Sandiganbayan judicially determines probable cause for arrest, issues concerning the Ombudsman's executive determination become moot. The Court found that the Sandiganbayan's judicial determination was based on evidence showing a prima facie case, sufficient for issuing arrest warrants. The arguments raised by petitioners regarding the preparation of SAROs/NCAs, Relampagos' ministerial role, lack of evidence against other petitioners, and the nature of Luy's testimony were deemed matters relating to the Ombudsman's finding, which were rendered moot by the Sandiganbayan's judicial determination. The Court emphasized that probable cause for arrest requires only a probability of guilt, not absolute certainty, and can be based on hearsay evidence if there is a substantial basis for its credibility. On the Motion to Hold in Abeyance the Issuance of Warrants of Arrest and On the Motion for Bill of Particulars: The Court agreed with the Sandiganbayan that the motion to hold in abeyance became moot upon the issuance of the warrants of arrest against the petitioners. The Court was not persuaded that the Informations lacked sufficient particularity. It found that the petitioners were able to intelligently address the charges against them. The Court concluded that the factual and legal issues raised by the petitioners were evidentiary matters and defenses that should be passed upon during a full-blown trial on the merits. The Court found no evidence of grave abuse of discretion, capricious or whimsical exercise of judgment, or arbitrary and despotic exercise of power by the Sandiganbayan in its finding of probable cause.
Main Doctrine
The judicial determination of probable cause by the Sandiganbayan for the issuance of a warrant of arrest is distinct from the executive determination of probable cause by the Ombudsman for indictment, and the former renders moot issues raised concerning the latter. Probable cause for arrest can be established with hearsay evidence, provided there is a substantial basis for crediting it, and the standard is less stringent than that for conviction.