Organo v. Sandiganbayan
NEW DOCTRINEFacts
The Antecedents: An Information was filed with the Sandiganbayan against petitioner Lilia B. Organo and others for the crime of plunder under R.A. No. 7080, as amended by R.A. No. 7659. The Information alleged that the accused, taking advantage of their official positions as employees of the Bureau of Internal Revenue, Region 7, Quezon City, conspired to amass and acquire funds belonging to the National Government by opening an unauthorized bank account and depositing therein revenue tax payments, from which they withdrew P193,565,079.64 between November 1996 and February 1997, misappropriating said funds for their personal gain. Procedural History: Petitioner filed a motion to quash the information with the Sandiganbayan, contending that the Sandiganbayan no longer had jurisdiction over the case under R.A. 8249, approved on February 5, 1997. The Sandiganbayan issued a warrant of arrest without resolving the motion. Subsequently, the Sandiganbayan denied the motion to quash for lack of merit. Petitioner filed a motion for reconsideration, reiterating the ground of lack of jurisdiction. After 140 days, the Sandiganbayan denied the motion for reconsideration, ruling that petitioner should first surrender to the court before filing any further pleading. The Petition: Petitioner filed a special civil action for certiorari with preliminary injunction or temporary restraining order assailing the resolutions of the Sandiganbayan.
Issue(s)
Whether the Sandiganbayan had jurisdiction over the crime of plunder at the time the information was filed, considering the enactment of Republic Act No. 8249. Whether the Sandiganbayan committed a serious error of jurisdiction in denying the motion to quash and motion for reconsideration.
Ruling
The Court grants the petition for certiorari and annuls the resolutions of the Sandiganbayan dated November 20, 1997, and April 28, 1998. The Court orders the Sandiganbayan to forthwith refer the case to the court of proper jurisdiction.
Ratio Decidendi
On the issue of Sandiganbayan jurisdiction over plunder under R.A. 8249: The Court ruled that the Sandiganbayan has no jurisdiction over the crime of plunder unless committed by public officials and employees occupying positions with Salary Grade "27" or higher, under the Compensation and Position Classification Act of 1989 (Republic Act No. 6758) in relation to their office. Republic Act No. 7080, which defines plunder, provisionally placed such cases within the Sandiganbayan's jurisdiction "until otherwise provided by law." Republic Act No. 8249, enacted on February 5, 1997, is the special law that provided for the jurisdiction of the Sandiganbayan "otherwise" than that prescribed in Republic Act No. 7080. This new law collated the provisions on the exclusive jurisdiction of the Sandiganbayan and was enacted to declog the Sandiganbayan of "small fry" cases, making its original jurisdiction dependent not on the penalty but on the rank and salary grade of the accused public officials and employees. Therefore, at the time the information was filed on August 15, 1997, R.A. 8249 was already in effect, and the Sandiganbayan's jurisdiction was limited to cases involving public officers with Salary Grade "27" or higher. On whether the Sandiganbayan committed a serious error of jurisdiction: The Court found that the Sandiganbayan incurred in serious error of jurisdiction by ruling in favor of its jurisdiction over the plunder case, even though none of the accused occupied positions with Salary Grade "27" or higher under R.A. 6758. The Sandiganbayan's position that R.A. 7080 vests it with jurisdiction and that it constitutes an exception to R.A. 8249 was incorrect. R.A. 8249 specifically amended the jurisdiction of the Sandiganbayan, and the plunder law's provision "until otherwise provided by law" was superseded by R.A. 8249. Consequently, the Sandiganbayan should have dismissed the case for lack of jurisdiction, as the case should have been referred to the court of proper jurisdiction, which would be the Regional Trial Court if the Salary Grade requirement was not met.
Main Doctrine
The Sandiganbayan has no jurisdiction over the crime of plunder unless committed by public officials and employees occupying positions with Salary Grade "27" or higher, under the Compensation and Position Classification Act of 1989 (Republic Act No. 6758) in relation to their office, following the enactment of Republic Act No. 8249.