Commission on Elections v. Noynay
REITERATIONFacts
The Antecedents: The Commission on Elections (COMELEC) resolved to file informations for violation of Section 261(i) of the Omnibus Election Code against public school principal Diosdada Amor and teachers Esbel Chua and Ruben Magluyoan for engaging in partisan political activities. Nine informations were filed with the Regional Trial Court (RTC), Branch 23, Allen, Northern Samar. Procedural History: The RTC, motu proprio, ordered the records withdrawn and directed the COMELEC Law Department to refile the cases with the appropriate Municipal Trial Court (MTC), reasoning that R.A. No. 7691 amended B.P. Blg. 129, divesting RTCs of jurisdiction over offenses punishable by imprisonment not exceeding six years. The COMELEC's motions for reconsideration were denied. The Petition: The COMELEC filed a special civil action for certiorari with mandamus, contending that the RTC erroneously construed R.A. No. 7691 and that, pursuant to Section 268 of the Omnibus Election Code and jurisprudence, RTCs have exclusive original jurisdiction over election offenses.
Issue(s)
Whether R.A. No. 7691 divested Regional Trial Courts of jurisdiction over election offenses punishable with imprisonment not exceeding six (6) years. Whether the Regional Trial Court has exclusive original jurisdiction over election offenses.
Ruling
The petition is GRANTED. The challenged orders of respondent Judge Tomas B. Noynay dated August 25, 1997, and October 17, 1997, in Criminal Cases Nos. A-1439 and A-1442 to A-1449 are SET ASIDE. Respondent Judge is DIRECTED to try and decide said cases with purposeful dispatch and, further, ADMONISHED to faithfully comply with Canons 4 and 18 of the Canons of Judicial Ethics and Rule 3.01, Canon 3 of the Code of Judicial Conduct. Atty. Jose P. Balbuena is ADMONISHED to be more careful in the discharge of his duty to the court as a lawyer under the Code of Professional Responsibility.
Ratio Decidendi
On the issue of whether R.A. No. 7691 divested Regional Trial Courts of jurisdiction over election offenses punishable with imprisonment not exceeding six (6) years: The Supreme Court held that R.A. No. 7691, which expanded the jurisdiction of Metropolitan, Municipal Trial, and Municipal Circuit Trial Courts, did not divest Regional Trial Courts (RTCs) of their exclusive original jurisdiction over election offenses. This is because Section 32 of B.P. Blg. 129, as amended by R.A. No. 7691, contains an explicit exception clause: "Except in cases falling within the exclusive original jurisdiction of Regional Trial Court and of the Sandiganbayan." This exception preserves the jurisdiction of RTCs over cases specifically vested in them by law, regardless of the imposable penalty. The Court emphasized that jurisdiction is conferred by law, and Congress has the power to define and apportion it. Special laws, such as Section 268 of the Omnibus Election Code which grants RTCs exclusive original jurisdiction over election offenses, must be construed as exceptions to the general law on court jurisdiction. Therefore, R.A. No. 7691, being a general amendatory law, does not repeal or modify special provisions vesting jurisdiction in the RTCs. The Court noted that the exception clause in Section 32 of B.P. Blg. 129 was not removed by the amendment, indicating no intent to divest RTCs of jurisdiction over these specific offenses. The respondent judge's failure to consider this opening sentence of Section 32 was deemed an oversight. On the issue of whether the Regional Trial Court has exclusive original jurisdiction over election offenses: The Court affirmed that Section 268 of the Omnibus Election Code explicitly grants RTCs the exclusive original jurisdiction to try and decide any criminal action or proceedings for violation of the Code, except for offenses relating to failure to register or failure to vote. The offense in question, violation of Section 261(i) of the Omnibus Election Code, falls under this exclusive jurisdiction. The penalty for such offenses, as provided in Section 264, is imprisonment of not less than one year but not more than six years. The Court reiterated its ruling in Morales v. Court of Appeals, which clarified that the expanded jurisdiction of lower courts under R.A. No. 7691 does not encroach upon cases falling within the exclusive original jurisdiction of RTCs or the Sandiganbayan, irrespective of the penalty. Thus, election offenses, by specific provision of law, remain within the exclusive original jurisdiction of the RTCs.
Main Doctrine
Regional Trial Courts retain exclusive original jurisdiction over election offenses, notwithstanding the expanded jurisdiction of Metropolitan, Municipal Trial, and Municipal Circuit Trial Courts under R.A. No. 7691, due to the specific provision in Section 268 of the Omnibus Election Code and the exception clause in Section 32 of B.P. Blg. 129.