Ampongan v. Sandiganbayan
CLARIFICATIONFacts
The Antecedents: Petitioner Omar Erasmo Gonowon Ampongan was the Vice Mayor of Iriga City, Camarines Sur, with a salary grade of 26. On November 3, 2014, Ampongan allegedly appointed Edsel S. Dimaiwat to the position of Secretary to the Sangguniang Panlungsod. The prosecution alleged that Ampongan acted with evident bad faith or gross inexcusable negligence by making it appear in the Civil Service Commission (CSC) appointment papers that Dimaiwat had been screened and found qualified by the Personnel Selection Board, when in fact no such screening or deliberation had occurred. Procedural History: On July 14, 2017, the Office of the Special Prosecutor filed two Informations against Ampongan in the Sandiganbayan: one for violation of Section 3(e) of R.A. No. 3019 and another for Falsification of Public Document under Article 171(2) of the Revised Penal Code (RPC). Ampongan filed a motion to quash the Informations, arguing that the Sandiganbayan lacked jurisdiction because he was only Salary Grade 26 and the Informations did not allege damage to the government exceeding One Million Pesos (P1,000,000.00), as required by R.A. No. 10660. The Sandiganbayan denied the motion on September 29, 2017, ruling that R.A. No. 10660's damage requirement only applied to offenses committed after May 15, 2015, and that Vice Mayors are specifically included in its jurisdiction under R.A. No. 8249. The Petition: Ampongan filed a petition for certiorari under Rule 65 of the Rules of Court, alleging that the Sandiganbayan committed grave abuse of discretion. He argued that since R.A. No. 10660 was the law in force at the time the Informations were filed in 2017, its provisions should govern, thereby divesting the Sandiganbayan of jurisdiction in favor of the Regional Trial Court (RTC) because the Informations lacked allegations of damage or bribery exceeding the statutory threshold.
Issue(s)
Whether the Sandiganbayan has jurisdiction over a City Vice Mayor with Salary Grade 26 for offenses committed prior to the effectivity of R.A. No. 10660. Whether the crime of Falsification of Public Document under Article 171(2) of the RPC was committed in relation to the petitioner's office.
Ruling
The petition for certiorari is DISMISSED. The Sandiganbayan's Order is AFFIRMED.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Sandiganbayan has jurisdiction. While jurisdiction is typically determined at the time of filing, R.A. No. 10660 contains an express transitory provision in Section 5, which states that the amendments to the Sandiganbayan's jurisdiction apply only to cases arising from offenses committed after the law's effectivity on May 5, 2015. Since Ampongan's alleged offenses were committed on November 3, 2014, the applicable law is R.A. No. 8249. Under R.A. No. 8249, City Vice Mayors are specifically enumerated as officials falling under the Sandiganbayan's exclusive original jurisdiction. Applying the doctrine in Inding v. Sandiganbayan, the Court held that the specific inclusion of certain officials in the law constitutes an exception to the general Salary Grade 27 requirement. Therefore, the Sandiganbayan retains jurisdiction over a Vice Mayor regardless of their salary grade for offenses committed before May 5, 2015. On Issue 2: The Court held that the crime of Falsification of Public Document was committed in relation to the petitioner's office. An offense is deemed committed in relation to office when the office is an element of the crime or when the offense is intimately connected with the discharge of official functions. Citing Alarilla v. Sandiganbayan, the Court noted that the Information explicitly alleged that Ampongan, in his capacity as Vice Mayor and while performing his official functions, took advantage of his position to falsify the CSC appointment paper. The act of signing and processing appointment papers for the Sangguniang Panlungsod is an official function of the Vice Mayor. Consequently, the falsification charge is intimately connected to his office, placing it within the Sandiganbayan's jurisdiction as an offense committed in relation to office.
Main Doctrine
While the jurisdiction of a court is generally determined at the time of the institution of the action, the specific transitory provision of R.A. No. 10660 dictates that its amendments to the Sandiganbayan's jurisdiction apply only to offenses committed after its effectivity on May 5, 2015. Consequently, for offenses committed prior to this date, the Sandiganbayan retains jurisdiction over specifically enumerated officials (such as City Vice Mayors) under R.A. No. 8249, regardless of whether their salary grade is below 27 or whether the information alleges damage to the government exceeding One Million Pesos.