182001-04 and Marquez vs. Sandiganbayan G.R. Nos. 182020-24, Sep. 2, 2009)

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We are not unmindful of the fact that petitioners failed to conduct the requisite

public bidding for the questioned procurements. However, the lack of public bidding
alone does not automatically equate to a manifest and gross disadvantage to the
government. As we had occasion to declare in Nava v. Sandiganbayan,[22] the
absence of a public bidding may mean that the government was not able to secure
the lowest bargain in its favor xxx (Caunan vs. People of the Phils G.R. Nos. 181999 &
182001-04 and Marquez vs. Sandiganbayan G.R. Nos. 182020-24, Sep. 2, 2009)

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