Facts: The case revolves around a series of loan transactions granted by the Philippine National Bank (PNB) to Integrated Shoe, Inc. (ISI), highlighting the alleged involvement of petitioner Gregorio Singian, Jr. The following step-by-step events are relevant to the case:
1. In January 1972, ISI applied for a US$2,500,000.00 letter of credit from PNB to acquire machinery and equipment, which was recommended by PNB’s Senior Vice-President and subsequently approved by PNB with specific conditions and collateral requirements.
2. From February 1972 to December 1980, ISI obtained multiple loans from PNB amounting to over P71 million, characterized by the Committee investigating behest loans as lacking adequate collateral.
3. On March 20, 1996, Atty. Orlando Salvador filed a complaint for violation of RA 3019, Section 3(e) and (g), against several individuals, including Singian, with the Ombudsman, following the Committee’s findings.
4. The Ombudsman’s investigation led to 18 Informations for violations of RA 3019 being filed against Singian and others in Sandiganbayan, Third Division, each corresponding to the loans granted to ISI.
5. The Sandiganbayan dismissed some charges and cases against certain accused due to death, while the trial proceeded against Singian and others alive.
6. The prosecution presented documentary evidence and testimony primarily indicating ISI’s undercapitalized state during many loan grants, with evidence that the loan was disadvantageous to the government.
7. Singian filed a demurrer to evidence claiming lack of conspiracy evidence, adequately secured loans, and his non-involvement as he wasn’t on ISI’s Board.
8. The Sandiganbayan denied the demurrer on grounds of sufficient evidence against Singian, prompting him to file a certiorari with the Supreme Court.
Issues: The Supreme Court deliberated on several legal issues, including:
1. Whether a conspiracy existed involving Singian to commit the alleged transaction crimes.
2. Whether the loans were indeed behest loans that disadvantaged the government.
3. Whether due process was denied by the Sandiganbayan in rejecting Singian’s demurrer and motion for reconsideration.
4. Whether the presented prosecution documents were admissible and competent evidence.
Court’s Decision: The Supreme Court dismissed Singian’s petition:
1. On conspiracy: The Court held that there was sufficient evidence to establish conspiracy due to observed patterns in loan transactions, where Singian’s involvement and relational ties with key ISI and PNB personnel indicated a possible conspiracy.
2. On behest loans: The Court found supporting evidence to maintain the characterization of the loans as manifestly and grossly disadvantageous to the government, noting ISI’s failure to meet collateral and capital requirements adequately.
3. On due process: The Court determined that Singian failed to show grave abuse of discretion, noting the Sandiganbayan’s reasoned ruling as within judicial discretion pertaining to the sufficiency of prosecution’s evidence.
4. On evidence admissibility: The Court upheld the Sandiganbayan’s acceptance of the prosecution’s documentary evidence, including photocopied documents of the Fact-Finding Committee’s report.
Doctrine: The case reiterated doctrines concerning the Sandiganbayan’s discretion in ruling on demurrers to evidence and the parameters for establishing conspiracy, especially involving external private persons alongside public officials under the Anti-Graft and Corrupt Practices Act.
Class Notes:
– RA 3019 Sec. 3(e) and (g) require showing undue injury or disadvantages due to government contract mismanagement.
– Conspiracy can be inferred from concerted actions; involvement can extend from implied knowledge and relational ties.
– Demurrers to evidence challenge the sufficiency, not veracity, of evidence to sustain a charge.
– Legal remedies are circumscribed by procedural regularity and limits to certiorari appeal post-denial of a demurrer.
Historical Background: The case occurs during a heightened period of socioeconomic reform in post-Marcos governance within the Philippines, focusing on the redress of economic injustices like behest loans—a financial misconduct facilitating preferential loans at a national scale without adequate safeguard, leading to substantial public fund losses. The litigation reflects institutional efforts to rectify or recover losses from previous administrations’ corrupt practices under changing socio-political conditions.
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