Alarilla v. Sandiganbayan
REITERATIONFacts
The Antecedents: On December 1, 1995, two informations were filed against petitioner Eduardo A. Alarilla: one for grave threats (Criminal Case No. 23069) and another for violation of Section 3(e) of R.A. 3019 (Criminal Case No. 23070). Criminal Case No. 23070 was dismissed. Criminal Case No. 23069, assigned to the First Division of the Sandiganbayan, was amended to allege that the crime of grave threats was committed by petitioner, then Municipal Mayor of Meycauayan, Bulacan, in relation to and taking advantage of his official functions. Specifically, it alleged that petitioner willfully, unlawfully, and feloniously leveled and aimed a .45 caliber pistol at and threatened to kill Simeon G. Legaspi during a public hearing about factory pollution, after Legaspi delivered a privilege speech critical of petitioner's administration. Procedural History: The Sandiganbayan admitted the amended information. Petitioner's motion for reconsideration and motion for reinvestigation were denied, with the Sandiganbayan holding that the crime charged was "office-related" and thus within its jurisdiction. A prior petition for certiorari questioning these resolutions was dismissed by the Supreme Court for failure to sufficiently show grave abuse of discretion. Subsequently, after the prosecution presented its evidence in Criminal Case No. 23069, petitioner filed a demurrer to evidence, arguing that the elements of grave threats were not proven and that the act was not committed in relation to his official functions. The Sandiganbayan denied the demurrer in a resolution dated July 28, 1998, finding sufficient evidence on record. A motion for reconsideration was also denied on December 17, 1998. The Petition: Petitioner filed a petition for certiorari under Rule 65 of the Rules of Court, alleging that the Sandiganbayan gravely abused its discretion in denying his demurrer to evidence and his motion for reconsideration, and in ruling that the offense charged falls within its jurisdiction.
Issue(s)
Whether the Sandiganbayan gravely abused its discretion in denying petitioner's demurrer to evidence. Whether the Sandiganbayan acted without or in excess of its jurisdiction or with grave abuse of discretion in ruling that the offense charged falls within its jurisdiction. Whether petitioner should be granted injunctive relief.
Ruling
The petition for certiorari is DISMISSED.
Ratio Decidendi
On the denial of the demurrer to evidence: The resolution of a demurrer to evidence is left to sound judicial discretion and will not be disturbed by appellate courts unless there is a showing of grave abuse of discretion. The petitioner failed to establish that the Sandiganbayan's denial of his demurrer was capricious, arbitrary, or whimsical. The Sandiganbayan found that the prosecution's evidence sufficiently established the elements of the crime of grave threats, and the petitioner did not present evidence to rebut this finding. The Court reiterated that mere allegations of abuse of discretion are insufficient to warrant the issuance of a writ of certiorari. On the Sandiganbayan's jurisdiction: The jurisdiction of the Sandiganbayan is determined by the allegations in the information. Under PD 1606, as amended by RA 7975, the Sandiganbayan exercises original jurisdiction over offenses committed by public officials in relation to their office. The amended information alleged that the petitioner, as Municipal Mayor, committed grave threats against Simeon G. Legaspi during a public hearing, after Legaspi criticized the petitioner's administration. The Court found that the offense charged was intimately connected with the discharge of the petitioner's official functions, as his actions were precipitated by criticism of his administration and occurred during a public hearing where he was performing his official duty as mayor. The Sandiganbayan correctly assumed jurisdiction based on these allegations. On injunctive relief: The petition for certiorari was dismissed, rendering the prayer for injunctive relief moot.
Main Doctrine
The Sandiganbayan's jurisdiction over offenses committed by public officers in relation to their office is determined by the allegations in the information, and the denial of a demurrer to evidence will not be disturbed absent a showing of grave abuse of discretion.