Mayor Francisco Lecaroz v. Sandiganbayan
REITERATIONFacts
The Antecedents: The petitioner, Mayor Francisco Lecaroz, was charged with grave coercion. The information alleged that on or about July 2, 1979, in Sta. Cruz, Marinduque, the petitioner, taking advantage of his position as mayor, unlawfully and feloniously took over the operation and control of a gasoline station owned by Pedro Par. He allegedly sold the gasoline, issued invoices, and padlocked the dispensing pump without legal authority, thereby depriving Par of his business and compelling him to do something against his will through threat, force, or violence. Procedural History: Following the filing of the information and its subsequent amendment, the petitioner filed a motion to quash the information, arguing that the Sandiganbayan lacked jurisdiction and that the case should have been filed in the ordinary courts of Marinduque. The Sandiganbayan denied this motion. Consequently, the petitioner initiated a proceeding for certiorari before the Supreme Court, seeking the same relief. The Petition: The petitioner seeks a writ of certiorari, primarily arguing that the Sandiganbayan lacks jurisdiction. His arguments are threefold: (1) the offense charged is not related to his office as mayor; (2) grave coercion is not among the offenses enumerated in Section 4(c) of Presidential Decree No. 1486, as amended, over which the Sandiganbayan has jurisdiction; and (3) assuming jurisdiction, the Sandiganbayan abused its discretion in denying the transfer of the hearing to the Court of First Instance of Marinduque, given that all witnesses reside there.
Issue(s)
Whether the Sandiganbayan has jurisdiction over the crime of grave coercion allegedly committed by a mayor in relation to his office. Whether Section 4(c) of Presidential Decree No. 1486, as amended, is constitutional. Whether the Sandiganbayan committed grave abuse of discretion in denying the transfer of the hearing to the Court of First Instance of Marinduque.
Ruling
The petition is dismissed for lack of merit, and the temporary restraining order issued on March 12, 1982, is dissolved. The Sandiganbayan retains jurisdiction over the case.
Ratio Decidendi
On the jurisdiction of the Sandiganbayan over grave coercion committed by a public officer in relation to his office: The Supreme Court affirmed the Sandiganbayan's jurisdiction. Citing Section 5, Article XIII of the Constitution, the Court held that the Sandiganbayan has jurisdiction not only over graft and corrupt practices but also over "such other offenses committed by public officers and employees, in relation to their office as may be determined by law." Presidential Decree No. 1486, Section 4(c), as amended, explicitly grants the Sandiganbayan jurisdiction over "other crimes or offenses committed by public officers or employees... in relation to their office." The Court found that the information clearly alleged that the petitioner, as mayor, took advantage of his public position to commit the acts constituting grave coercion, making the offense directly related to his office. The Court emphasized that if the petitioner were not the mayor, he would not have been able to order his policemen to commit the acts, nor would the policemen have followed such orders. Therefore, the offense was committed in relation to his office, falling within the Sandiganbayan's jurisdiction. On the constitutionality of Section 4(c) of Presidential Decree No. 1486: The Court found no merit in the petitioner's contention that Section 4(c) of PD 1486 enlarges the jurisdiction granted by Section 5, Article XIII of the Constitution. The Court explained that the constitutional provision delegates to the lawmaking body the determination of "such other offenses" over which the Sandiganbayan shall have jurisdiction. The President, exercising lawmaking authority, issued PD 1486, which included all public office-related offenses. The Court held that when the lawmaking authority includes such offenses, the courts will not review questions of legislative policy, as long as the act is within the constitutional power of the lawmaking body. Thus, the provision was deemed constitutional. On the Sandiganbayan's denial of the transfer of hearing and concurrent jurisdiction: The Court ruled that the Sandiganbayan did not commit grave abuse of discretion in denying the transfer of the hearing. The crime of grave coercion, as penalized by Article 286 of the Revised Penal Code, falls under the concurrent jurisdiction of the Sandiganbayan and the regular courts, pursuant to Section 4 of PD 1606, as amended. The established rule is that the court that first acquires jurisdiction must continue exercising it to the exclusion of others. Since the information was filed with the Sandiganbayan in 1980, it had already acquired jurisdiction. Furthermore, the Court noted that even if PD 1861 amended PD 1606 to exclude certain offenses from the Sandiganbayan's concurrent jurisdiction, Section 2 of PD 1861 explicitly states that all pending cases shall remain with the courts where they are pending. Therefore, the Sandiganbayan retained jurisdiction over the petitioner's case.
Main Doctrine
The Sandiganbayan has jurisdiction over offenses committed by public officers in relation to their office, as determined by law, including grave coercion, even if the penalty is relatively light, provided the case was filed before the effectivity of amendatory decrees that would divest it of jurisdiction.