People v. Geduspan
REITERATIONFacts
The Antecedents: Petitioners Marilyn C. Geduspan, Regional Manager/Director of the Philippine Health Insurance Corporation (Philhealth) Region VI, and Dr. Evangeline C. Farahmand, Chairman of the Board of Directors of Tiong Bi Medical Center, Tiong Bi, Inc., were charged with violation of Section 3(e) of Republic Act No. 3019, as amended. The information alleged that Geduspan, in connivance with Farahmand, unlawfully released claims for payments amounting to ₱91,954.64 to Tiong Bi Medical Center, despite a Deed of Conditional Sale stipulating that collectibles accruing prior to January 1, 2000, shall be due to West Negros College, Inc. This allegedly gave unwarranted benefits to Tiong Bi, Inc. to the damage of West Negros College, Inc. Procedural History: Both accused filed a joint motion to quash, contending that the Sandiganbayan lacked jurisdiction because Geduspan, as Regional Director of Philhealth, held a position classified under salary grade 26, which they argued was outside the Sandiganbayan's jurisdiction based on Section 4 of RA 8249. The Sandiganbayan denied the motion to quash and the subsequent motion for reconsideration. The Petition: Petitioner Geduspan filed a petition for certiorari under Rule 65 of the Rules of Court, seeking to annul the Sandiganbayan's resolutions, arguing that the court gravely abused its discretion in assuming jurisdiction over her person.
Issue(s)
Whether the Sandiganbayan has jurisdiction over a Regional Director/Manager of a government-owned or controlled corporation (GOCC) organized under the Corporation Code for purposes of RA 3019, considering the specific enumeration of managers in RA 8249. Whether petitioner Marilyn C. Geduspan's position as Department Manager A of Philhealth, classified under salary grade 26, falls within the jurisdiction of the Sandiganbayan, and whether the requisites for Sandiganbayan jurisdiction are met.
Ruling
The petition is dismissed for lack of merit. The Sandiganbayan has jurisdiction over the petitioner. Costs against the petitioner.
Ratio Decidendi
On the jurisdiction of the Sandiganbayan over managers of GOCCs: The Court clarified that while Section 4(a)(1) of RA 8249, as amended, pertains to officials of the executive branch occupying positions of regional director and higher, classified as Grade '27' and higher, the same section "specifically includes" other officials. Paragraph (g) of Section 4(a)(1) explicitly enumerates "Presidents, directors or trustees, or managers of government-owned and controlled corporations" as falling under the jurisdiction of the Sandiganbayan. Therefore, the position of manager in a GOCC, such as Philhealth, is within the Sandiganbayan's jurisdiction, irrespective of the salary grade classification of the position. On petitioner's position, salary grade, and the requisites for Sandiganbayan jurisdiction: The Court noted that while petitioner claimed to be a Regional Director/Manager, her appointment paper and notice of salary adjustment indicated her position as Department Manager A. The Court emphasized that it is the position held by the petitioner, not merely her salary grade, that determines the jurisdiction of the Sandiganbayan. Even if her position was classified under salary grade 26, the specific inclusion of managers of GOCCs in RA 8249, regardless of salary grade, is controlling. The Court distinguished the present case from Ramon Cuyco v. Sandiganbayan, where the accused's position as Regional Director was classified as Director II with salary grade 26 at the time of the offense, and thus outside the Sandiganbayan's jurisdiction under the prevailing law at that time. In this case, the specific inclusion of managers of GOCCs in RA 8249, regardless of salary grade, is controlling. Citing Lacson v. Executive Secretary, et al., the Court reiterated that for the Sandiganbayan to exercise jurisdiction, three requisites must concur: (1) the offense committed is a violation of RA 3019, RA 1379, bribery, sequestration cases, or other felonies; (2) the offender is a public official holding one of the enumerated positions; and (3) the offense was committed in relation to the office. The Court found that petitioner was a public officer, a department manager of Philhealth (a GOCC), the offense charged was a violation of RA 3019, and it was committed in relation to her office. Thus, all requisites were met, confirming the Sandiganbayan's jurisdiction.
Main Doctrine
The Sandiganbayan has jurisdiction over managers of government-owned or controlled corporations, regardless of their salary grade, when charged with violations of RA 3019, as amended, committed in relation to their office, as provided under Section 4(a)(1)(g) of RA 8249.