Hunnob v. People
REITERATIONFacts
The Antecedents: Petitioners Roy Hunnob (barangay captain) and Salvador Galeon (barangay treasurer) were charged with violation of Section 3(e) of RA 3019 for allegedly facilitating the payment of P67,200.00 to Caroline B. Hunnob, Roy Hunnob's sister, for the fictitious delivery of a 25 horsepower speedboat. The grant for the purchase was P70,000.00 from the Provincial Government of Ifugao. Roy Hunnob allegedly kept the grant secret, purchased an old Evinrude 25-HP motor engine instead of a Johnson 25-HP motor engine, and did not follow proper procurement procedures, such as having multiple suppliers and proper documentation. The Commission on Audit (COA) disallowed the purchase, and the amount was returned by Caroline Hunnob. Procedural History: The Regional Trial Court (RTC), Branch 14, Lagawe, Ifugao, found both petitioners guilty of violating Section 3(e) of RA 3019 and sentenced them to an indeterminate penalty of six (6) years and one (1) month to nine (9) years and eight (8) months, with perpetual disqualification from holding public office. On appeal, the Court of Appeals (CA) affirmed the RTC's decision. Petitioners' motion for reconsideration was denied by the CA. The Petition: Petitioners filed a Petition for Review on Certiorari before the Supreme Court, invoking good faith and asserting their intention was to acquire the motor engine for the barangay, with Caroline Hunnob being the only available supplier. They also argued that the amount was returned, thus no injury occurred.
Issue(s)
Whether the Court of Appeals has appellate jurisdiction over the trial court's verdict of conviction for violation of Section 3(e) of RA 3019. Whether petitioners Roy Hunnob and Salvador Galeon are guilty of violating Section 3(e) of RA 3019.
Ruling
The Supreme Court vacated the Decision and Resolution of the Court of Appeals, and directed the Court of Appeals to immediately remand the case records to the Regional Trial Court, Branch 14, Lagawe, Ifugao, which shall then transmit the same to the Sandiganbayan, with utmost dispatch. The Court found that the Court of Appeals acted without jurisdiction.
Ratio Decidendi
On the issue of appellate jurisdiction: The Court held that the Court of Appeals does not have appellate jurisdiction over appeals from final judgments, resolutions, or orders of regional trial courts pertaining to violations of RA 3019 when the accused are officials occupying positions corresponding to Salary Grades below 27. Section 4 of PD 1606 clearly vests exclusive appellate jurisdiction in such cases to the Sandiganbayan. Petitioners, as barangay captain and barangay treasurer, held positions corresponding to Salary Grades below 27. Therefore, their appeal should have been filed with the Sandiganbayan, not the Court of Appeals. The Court emphasized that the erroneous transmission of records to the Court of Appeals by the clerk of court does not prejudice the petitioners, as they are not responsible for this procedural error. The Supreme Court, citing Dizon v. People, ruled that petitioners should not be prejudiced by the clerk of court's mistake, especially when their life and liberty are at stake. Consequently, the rulings of the Court of Appeals were rendered without jurisdiction and are therefore void. On the substantive issue of guilt (obiter dictum): Although the primary ruling was on jurisdiction, the Court noted that the RTC found petitioners guilty of violating Section 3(e) of RA 3019. The RTC found that Caroline Hunnob should have been disqualified from bidding as she was Roy Hunnob's sister, a relative within the third civil degree. The procurement process, even if considered 'Shopping,' failed to comply with the requirement of three price quotations, as only one came from Caroline Hunnob. The RTC concluded that conspiracy was proven by their signatures on the documents. The Court of Appeals affirmed this finding. However, due to the jurisdictional defect, the Supreme Court did not pass upon the merits of the conviction.
Main Doctrine
The Court of Appeals does not have appellate jurisdiction over appeals from final judgments, resolutions or orders of regional trial courts pertaining to violations of RA 3019 when the accused are officials whose positions correspond to Salary Grades below 27. Such appeals fall under the exclusive appellate jurisdiction of the Sandiganbayan. Rulings rendered by the Court of Appeals in such cases are void for lack of jurisdiction.