Non v. Office of the Ombudsman
NEW DOCTRINEFacts
The Antecedents: This case stems from the Energy Regulatory Commission's (ERC) issuance of Resolution No. 1, Series of 2016, which postponed the effectivity of Resolution No. 13, Series of 2015. The latter resolution mandated that all distribution utilities (DUs) conduct a competitive selection process (CSP) for securing power supply agreements (PSAs). The Alyansa Para sa Bagong Pilipinas (ABP) alleged that Resolution No. 1-2016 was a maneuver to favor Manila Electric Company (MERALCO) and its affiliates, allowing them to secure lucrative PSAs without adhering to the CSP requirement. This led to the filing of a complaint with the Office of the Ombudsman against the petitioners, who were then Commissioners of the ERC, for violations of the Anti-Graft and Corrupt Practices Act, the Code of Conduct and Ethical Standards for Public Officials and Employees, and the Electric Power Industry Reform Act of 2001, among other charges. Procedural History: The ABP filed a petition with the Supreme Court in G.R. No. 227670 assailing Resolution No. 1-2016 and the CSP Guidelines. Subsequently, the ABP filed a complaint with the Ombudsman, leading to administrative and criminal cases. The criminal complaint resulted in an Information filed before the Regional Trial Court (RTC) of Pasig City, docketed as Criminal Case No. R-PSG-18-01280-CR, charging the petitioners and another official with violation of Section 3(e) of R.A. No. 3019. The petitioners filed a Motion to Quash, arguing that the RTC lacked jurisdiction based on R.A. No. 10660, which stipulates that such cases should be tried in a judicial region other than where the official holds office. The RTC denied this motion, and a subsequent motion for reconsideration was also denied. The petitioners then filed an Urgent Motion for TRO/Writ of Preliminary Injunction, asserting a prejudicial question existed and reiterating the jurisdictional issue. Despite the ongoing proceedings, the Supreme Court later declared the assailed ERC issuances void ab initio in G.R. No. 227670. The petitioners subsequently filed a Supplemental Petition, which was docketed as the present case, G.R. No. 251177. The Petition: The petitioners are before the Supreme Court via a Petition for Certiorari under Rule 65 of the Rules of Court, assailing the Orders of the RTC, Branch 155, Pasig City, which denied their Motion to Quash and Motion for Reconsideration. The sole issue raised is that the RTC gravely erred in denying the Motion to Quash because, pursuant to R.A. No. 10660, it lacks jurisdiction over the criminal case, which must be tried in a judicial region other than the National Capital Judicial Region where the officials hold office. Petitioners contend that R.A. No. 10660, effective in 2015, clearly dictates the venue for such cases, and its application is not contingent on the Supreme Court promulgating implementing rules. They argue that the RTC's reliance on default rules for venue was erroneous, as R.A. No. 10660 specifically addresses the jurisdiction and venue for cases involving public officials of their rank.
Issue(s)
Whether the Regional Trial Court (RTC) Pasig City acted without or in excess of jurisdiction or with grave abuse of discretion in denying the petitioners' Motion to Quash the Information. Whether the RTC Pasig City has jurisdiction over Criminal Case No. R-PSG-18-01280-CR, considering the provisions of Republic Act No. 10660.
Ruling
The Supreme Court granted the petition, annulled the Orders dated September 10, 2018 and October 22, 2018 of the RTC, Branch 155, Pasig City, for lack of jurisdiction, ordered Criminal Case No. R-PSG-18-01280-CR dismissed, and declared all actions and proceedings undertaken by the RTC in the case as null and void for lack of jurisdiction.
Ratio Decidendi
On the propriety of certiorari: The Court reiterated that while a denial of a motion to quash is generally not appealable and the proper remedy is to proceed to trial, direct resort to certiorari is allowed in meritorious cases where the court issued the order without or in excess of jurisdiction or with grave abuse of discretion, or when the interlocutory order is patently erroneous and appeal would not afford adequate relief. The Court found that the RTC Pasig City acted with grave abuse of discretion in denying the petitioners' motion to quash, warranting the instant petition. On the jurisdiction of the RTC Pasig City: The Court held that the RTC Pasig City acted with grave abuse of discretion in denying the motion to quash. It found the RTC's reasoning that the lack of Supreme Court-promulgated rules for R.A. No. 10660 necessitated the application of the default venue rule under Section 15(a), Rule 110 of the Revised Rules on Criminal Procedure to be specious. The Court emphasized that Section 2 of R.A. No. 10660 clearly vests jurisdiction in the RTC under specific conditions and mandates that such cases be tried in a judicial region other than where the accused official holds office. Since R.A. No. 10660 took effect in 2015, and the Information was filed in 2018 when petitioners were ERC Commissioners holding office in Pasig City, and the Information did not allege damage to the government or bribery, the case should have been filed in a judicial region outside the National Capital Judicial Region. The Court clarified that the proviso 'subject to the rules promulgated by the Supreme Court' does not suspend the application of the law's clear intention regarding venue, as jurisdiction is conferred by substantive law, and rules of procedure yield to it. The Court cited Senate deliberations supporting the intent to prevent public officials from exerting influence over RTC judges hearing their cases. Therefore, the RTC Pasig City had no jurisdiction over the case, rendering all its actions null and void.
Main Doctrine
The Regional Trial Court (RTC) acted with grave abuse of discretion in denying the Motion to Quash filed by the petitioners because, under Section 2 of Republic Act No. 10660, cases falling within the jurisdiction of the RTC, as amended, shall be tried in a judicial region other than where the official holds office. The proviso 'subject to the rules promulgated by the Supreme Court' does not suspend the application of the law's clear intention regarding venue.