FACTS:

The petitioner, a private individual, filed a Petition for Review on Certiorari to challenge the Sandiganbayan's Decision and Resolution convicting him and his co-accused of violating the Anti-Graft and Corrupt Practices Act. The petitioner argued that there was no proof of conspiracy and that his former counsel's incompetence violated his constitutional rights to due process and competent counsel.

The Office of the Special Prosecutor opposed the plea to reopen the case. The Supreme Court, upon reviewing the case, found that the petition had no merit. They provided an explanation on the distinction between questions of law and questions of fact, emphasizing that the findings of fact made by the trial court should be respected, unless there is a clear showing of abuse or misapprehension of facts.

In addition, the court examined the elements of the crime charged and concluded that the evidence presented supported the findings of the Sandiganbayan. The court further ruled that the petitioner failed to present any reason that would warrant the application of exceptions to the general rule.

ISSUES:

1. Whether the Sandiganbayan erred in declaring the existence of a conspiracy and in convicting the petitioner in the absence of proof beyond reasonable doubt of such conspiracy.

2. Whether the petitioner's constitutional rights to due process and to competent counsel were violated, warranting a reopening of the proceedings.

RULING:

1. The petition has no merit. The findings of fact made by the Sandiganbayan, especially when affirmed by the Court of Appeals, are binding and conclusive upon the Supreme Court. There is no clear showing of abuse, arbitrariness, or capriciousness committed by the Sandiganbayan. The evidence on record supports the Sandiganbayan's finding that the petitioner is guilty of the crime charged.

2. The petitioner's plea to reopen the case is denied. The Office of the Special Prosecutor opposed the reopening of the case, citing the principle that a client is bound by the action of his counsel. The petitioner failed to provide sufficient evidence to prove that his former counsel's alleged errors and incompetence violated his constitutional rights to due process and to competent counsel.

PRINCIPLES:

• A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Findings of fact made by a trial court are accorded the highest degree of respect and are binding on the Supreme Court, unless there is a clear disregard of the evidence before it.

• Private persons may be charged in conspiracy with public officers and held liable for offenses under Section 3 of Republic Act No. 3019, in accordance with the policy of the anti-graft law to repress acts of graft or corrupt practices committed by both public officers and private persons.