Abbot v. Mapayo
ABANDONMENTFacts
1. The Antecedents: Petitioner Teodoto B. Abbot, Chief of the Irrigation System of the Mal-River Project, National Irrigation Administration, was charged with Malversation Thru Falsification of Public Document. The Information alleged that Abbot falsified a payroll, making it appear that seven witnesses received P4,500.00 each, when four actually received P1,500.00 and three received P2,000.00, thereby misappropriating P19,500.00. 2. Procedural History: The case was initially filed before the Sandiganbayan but was transferred to the Regional Trial Court (RTC) pursuant to RA 7975. Abbot pleaded not guilty and filed an Omnibus Motion to dismiss, arguing that the alleged misappropriated funds were no longer public funds. The RTC denied this motion on October 29, 1996, and a subsequent Motion for Reconsideration was also denied on February 12, 1997. 3. The Petition: Abbot then filed a Petition for Certiorari with Prohibition before the Court of Appeals, assailing the RTC's orders and arguing that the trial court gravely abused its discretion by not dismissing the Information. The Court of Appeals, agreeing with the Office of the Solicitor General's opinion that it lacked jurisdiction, dismissed Abbot's petition. Abbot then filed the present Petition for Review on Certiorari with the Supreme Court, arguing that the Court of Appeals, not the Sandiganbayan, had jurisdiction over his petition.
Issue(s)
Whether the Court of Appeals has jurisdiction to entertain a Petition for Certiorari with Prohibition assailing orders of the Regional Trial Court in a criminal case originally cognizable by the Sandiganbayan. Whether the Regional Trial Court gravely abused its discretion amounting to lack of jurisdiction in denying the Omnibus Motion to dismiss the Information.
Ruling
The petition is denied. The assailed Decision of the Court of Appeals dismissing the Petition for Certiorari with Prohibition and its Resolution denying reconsideration are affirmed.
Ratio Decidendi
On the jurisdiction of the Court of Appeals: The Court held that the Sandiganbayan has exclusive original jurisdiction over petitions for the issuance of writs of mandamus, prohibitions, certiorari, habeas corpus, injunction, and other ancillary writs and processes in aid of its appellate jurisdiction, as expanded by Section 4(c) of RA 7975. This provision amended PD 1606 and was in force at the time of the offense. Therefore, the Court of Appeals correctly concluded it was without jurisdiction to entertain the petition, as such jurisdiction was vested in the Sandiganbayan. The ruling in Garcia, Jr. v. Sandiganbayan, which held that the Sandiganbayan could not exercise jurisdiction over such petitions in the absence of a specific statutory grant, was supplanted by RA 7975. Consequently, no grave abuse of discretion could be imputed to the Court of Appeals for refusing to take cognizance of the petition. On the alleged grave abuse of discretion by the RTC: Since the Court affirmed the CA's dismissal for lack of jurisdiction, it did not delve into the merits of whether the RTC committed grave abuse of discretion. The primary issue before the Supreme Court was the jurisdiction of the appellate courts, not the correctness of the RTC's denial of the Omnibus Motion.
Main Doctrine
The Sandiganbayan has exclusive original jurisdiction over petitions for the issuance of writs of mandamus, prohibitions, certiorari, habeas corpus, injunction, and other ancillary writs and processes in aid of its appellate jurisdiction, as expanded by RA 7975, which amended PD 1606.