Organo v. Sandiganbayan
REITERATIONFacts
The Antecedents: Lilia B. Organo was detained pursuant to a Warrant of Arrest issued by the Sandiganbayan (Fourth Division) in connection with an Information for plunder under Republic Act No. 7080. The Information alleged that Organo, along with other public officers and employees of the Bureau of Internal Revenue, conspired to amass and acquire funds belonging to the National Government by opening an unauthorized bank account and withdrawing P193,565,079.64. Procedural History: Lilia B. Organo filed a Motion to Quash Information for lack of jurisdiction and to defer the issuance of a warrant of arrest. The case was raffled to the First Division and later unloaded to the respondent court, the Fourth Division. A warrant of arrest was issued on September 29, 1997. Organo filed an Urgent Motion to Recall and/or Quash Warrant of Arrest, which was denied on November 20, 1997. A Motion for Reconsideration was also denied on April 28, 1998. Organo then filed a petition for certiorari and prohibition with the Supreme Court, alleging lack of jurisdiction due to her salary grade being below 27 and grave abuse of discretion by the Sandiganbayan. Subsequently, Organo was arrested and detained. The Petition: Petitioner Fleurdeliz B. Organo filed a Petition for Habeas Corpus praying for the release of her mother, Lilia B. Organo, arguing that the Sandiganbayan had no jurisdiction over her mother because she did not occupy a position with Salary Grade 27 or higher.
Issue(s)
Does the Sandiganbayan have jurisdiction over a case of plunder when none of the accused occupy Salary Grade "27" or higher as provided under Republic Act No. 6758? Whether the Sandiganbayan gravely abused its discretion amounting to lack of jurisdiction in failing to act on the motion to quash before issuing a warrant of arrest.
Ruling
The Petition is GRANTED. The Manila jail warden is ORDERED to immediately release Lilia B. Organo from custody, unless a valid information has been filed in the proper court and a warrant for her arrest properly issued. Costs against petitioner.
Ratio Decidendi
On the jurisdiction of the Sandiganbayan over plunder cases: The Court ruled that the Sandiganbayan's jurisdiction over plunder cases is limited to public officials and employees occupying positions with Salary Grade 27 or higher. While Republic Act No. 7080 initially placed all plunder prosecutions within the Sandiganbayan's jurisdiction, Republic Act No. 8249, enacted subsequently, amended this by confining the Sandiganbayan's jurisdiction to cases involving public officials with Salary Grade 27 or higher. The Court clarified that plunder, being a crime committed by public officials in relation to their office, falls under Section 4(b) of RA 8249, which covers "Other offenses or felonies whether simple or complexed with other crimes committed by the public officials and employees mentioned in subsection (a) of this section in relation to their office." Therefore, RA 7080 was impliedly repealed by RA 8249 concerning the jurisdiction of the Sandiganbayan over plunder cases, making the salary grade of the accused a determinative factor. On the Sandiganbayan's grave abuse of discretion: Although the petition was granted on the ground of lack of jurisdiction, the Court noted the procedural impropriety of filing a separate Petition for Habeas Corpus when a Petition for Certiorari raising the same issue was already pending before the Supreme Court. The Court expressed displeasure at the attempt to vex the Court twice for the same relief, even though forum shopping might not be strictly present as the petitioner in the habeas corpus case was not a party to the certiorari case. The Court emphasized that a motion for release in the pending certiorari case would have been more expeditious and appropriate.
Main Doctrine
The Sandiganbayan's jurisdiction over plunder cases is limited to public officials occupying positions with Salary Grade 27 or higher, as provided by Republic Act No. 8249, which impliedly repealed the broader jurisdiction previously granted by Republic Act No. 7080.