People v. Sandiganbayan
REITERATIONFacts
The Antecedents: The underlying dispute arose from a complaint filed by Luis G. Pabalan against Manuel S. Alba, then City Administrator of Quezon City, and Jeremias T. Cruz, Chairman of Iglesia Evangelica Metodista En Las Islas Filipinas (IEMELIF). Pabalan alleged that IEMELIF, headed by Cruz, encroached upon his property and constructed improvements without a necessary building permit. The Quezon City building official ordered the demolition of the structure. However, Cruz wrote to Alba requesting that the demolition order be suspended pending an appeal to the DPWH, claiming the order was illegal and its enforcement would cause irreparable damage. Alba issued a memorandum recalling the demolition order on November 4, 1998, a day before his office received Cruz's letter. Pabalan objected and requested Alba to revoke the recall order, but Alba refused, preventing the demolition. Procedural History: A Graft Investigator found probable cause against Alba for violation of Section 3(e) of Republic Act No. 3019, and the Ombudsman approved the filing of an Information with the Sandiganbayan (SB). Alba filed a motion for leave to order reinvestigation and/or quash the Information, arguing that the finding of probable cause was unsupported by facts and evidence, and that the facts in the Information were based on erroneous premises. During a hearing, Alba agreed to convert his motion into a motion for reconsideration of the Ombudsman's resolution. The SB granted this, ordering the special prosecutor to take appropriate action. The Special Prosecutor later affirmed the finding of probable cause, and the SB set Alba for arraignment. Alba filed several motions, including a motion to reset his arraignment. The SB eventually issued an order holding the arraignment in abeyance pending resolution of the motion to quash. Despite this, Alba was arraigned on April 10, 2000, pleaded not guilty, and was granted leave to travel abroad. On June 23, 2000, the SB issued a Resolution granting Alba's motion to quash the information and acquitting him, finding no probable cause. The Petition: The People of the Philippines, through the Special Prosecutor's Office, filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to nullify the SB's Resolution. The petition argues that the SB committed grave abuse of discretion by acquitting Alba before he was arraigned or the prosecution allowed to prove its case, by granting the motion to quash based on a superseded memorandum, and by denying the petitioner its right to due process. The petitioner contends that the SB erred in relying on a January 12, 1994 memorandum which had been amended by a subsequent issuance (Memorandum No. 4) and was contrary to Section 307 of PD 1096. Furthermore, the petitioner asserts that Alba's motion to quash was effectively withdrawn when converted into a motion for reconsideration, and that his subsequent arraignment and posting of bail meant the SB had acquired jurisdiction, precluding dismissal for lack of probable cause. The petitioner argues that the SB's quashal of the Information on the premise of lack of probable cause, instead of merely dismissing the case, was a violation of case law and constituted grave abuse of discretion. The acquittal, without Alba praying for such relief, was also deemed an act without jurisdiction, depriving the petitioner of due process.
Issue(s)
Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction when it acquitted Manuel S. Alba of the crime charged despite not having been arraigned or the prosecution allowed to prove its case. Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction when it granted Manuel S. Alba's motion to quash on the basis of a Memorandum issued by the Quezon City Mayor, which had already been superseded. Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction when it denied the petitioner its right to due process.
Ruling
The petition is GRANTED. The assailed Resolutions of the Sandiganbayan are NULLIFIED. The records are remanded to the Sandiganbayan for further proceedings.
Ratio Decidendi
On the issue of the Sandiganbayan's grave abuse of discretion in acquitting respondent before arraignment: The Supreme Court ruled that the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction. The Court emphasized that the respondent had already been arraigned and had pleaded not guilty, and had posted bail for his provisional liberty. The SB's act of quashing the information and acquitting the respondent before trial, without the prosecution being given the opportunity to present its evidence, deprived the petitioner of its right to due process. The Court clarified that the absence of probable cause is a ground for dismissal of a case, not for quashing an information, and an acquittal requires a trial on the merits. On the issue of quashing the information based on a superseded Memorandum: The Supreme Court found that the Sandiganbayan erred in relying on the January 12, 1994 Memorandum of Mayor Ismael A. Mathay, Jr. The Court noted that this Memorandum had been superseded by subsequent issuances, specifically Memorandum No. 4, which clarified that the authority to act on violations of the Building Code no longer rested with the City Administrator but with the City Engineer or his assistant. Furthermore, the Court pointed out that the January 12, 1994 Memorandum was contrary to Section 307 of the National Building Code (P.D. No. 1096), which vests appellate jurisdiction over demolition orders with the Secretary of Public Works and Highways, not the City Administrator. The SB's reliance on an outdated and legally infirm basis for quashing the information constituted grave abuse of discretion. On the issue of denial of the petitioner's right to due process: The Supreme Court held that the Sandiganbayan's precipitate and patently illegal acts deprived the petitioner of its right to due process. By acquitting the respondent without trial and without the prosecution having had the chance to offer its evidence, the SB acted without jurisdiction. The Court cited jurisprudence stating that an order of dismissal issued when a case is not ready for trial and adjudication is null and void. The SB's action was an aberration that could not be countenanced, as it effectively aborted the prosecution's right to prove its case, thereby violating fundamental due process rights.
Main Doctrine
The Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction when it quashed the information and acquitted the respondent before arraignment and without the prosecution being allowed to prove its case, as the absence of probable cause is a ground for dismissal, not for quashing an information, and an acquittal requires a trial on the merits.