Co v. People
REITERATIONFacts
1. The Antecedents: Petitioners Aniceta R. Co (Barangay Chairman), Nestor B. Co (Barangay Kagawad and Bids and Awards Committee Chairman), and Emma L. Acebedo (Barangay Treasurer), low-ranking officials of Barangay 526, Manila, were charged with violating Section 3(e) of Republic Act No. 3019 for causing undue injury to government by awarding a motor vehicle procurement contract to Derexon Trading at a bid price of PHP 83,830.00 but purchasing it at PHP 120,283.00 via notarized Deed of Absolute Sale dated November 24, 2014, allowing post-award price modification in violation of Republic Act No. 9184, acting with evident bad faith, manifest partiality, and/or gross inexcusable negligence. The vehicle was previously owned by Nestor's brother Dominador Co and acquired by Derexon Trading shortly before sale. 2. Procedural History: Petitioners pleaded not guilty; RTC Branch 54, Manila convicted them on September 7, 2022 of violating Section 3(e) RA 3019, sentencing each to six years and one month minimum to 10 years maximum imprisonment and perpetual disqualification. Petitioners appealed to Court of Appeals (CA-G.R. CR No. 48751); CA affirmed on December 20, 2024 and denied reconsideration on May 29, 2025, finding gross inexcusable negligence in failing to verify vehicle registration and ownership. 3. The Petition: Petitioners filed a Petition for Certiorari under Rule 65 dated August 4, 2025, alleging CA committed grave abuse of discretion tantamount to lack of jurisdiction in affirming RTC conviction.
Issue(s)
Whether the Petition for Certiorari under Rule 65 is the proper remedy to assail the CA Decision affirming petitioners' conviction. Whether the CA had appellate jurisdiction over the RTC Decision convicting petitioners of violating Section 3(e) of Republic Act No. 3019.
Ruling
ACCORDINGLY, the Petition for Certiorari under Rule 65 dated August 4, 2025 filed by petitioners Aniceta R. Co, Nestor B. Co, and Emma L. Acebedo is DENIED. Nevertheless, the Decision dated December 20, 2024 and the Resolution dated May 29, 2025 of the Court of Appeals in CA-G.R. CR No. 48751 are VACATED. The Court of Appeals is DIRECTED to immediately REMAND the case records to Branch 54 of the Regional Trial Court of Manila, which shall transmit the same to the Sandiganbayan, with utmost dispatch. SO ORDERED.
Ratio Decidendi
On Issue 1: The proper remedy to assail the CA Decision affirming conviction is a petition for review on certiorari under Rule 45, not certiorari under Rule 65, as the latter is extraordinary, limited to jurisdictional errors, and unavailable when appeal exists. The Petition's caption conflicted but allegations invoked grave abuse on merits, not jurisdiction, rendering it a Rule 65 action, the wrong remedy since CA acted within apparent jurisdiction on merits. It suffered procedural infirmities: lacking certified true copy of CA Decision, only attaching Resolution and Compliance; defective verification omitting non-harassment allegation per Rule 7 Section 4; and bare of ultimate facts, issues, or arguments, merely reciting proceedings. Rule 46 Section 3 and Rule 65 Section 1 require strict attachment of documents, justifying outright dismissal. Procedural rules ensure orderly justice, preventing delays; thus, petition dismissed outright. (6 sentences) On Issue 2: Section 4 of Presidential Decree No. 1606, as amended by Republic Act No. 10660, vests Sandiganbayan with exclusive appellate jurisdiction over RTC final judgments in Republic Act No. 3019 violations where accused occupy positions below Salary Grade 27, as petitioners did. CA lacked jurisdiction as records were erroneously transmitted by RTC clerk post-notice of appeal, per Rule 122 Section 8 duty on clerk to transmit to proper appellate court. Applying Muñez v. People, Dizon v. People, Hunnob v. People, and Sideño v. People, CA rulings void despite proceeding on merits; accused not prejudiced by clerk's fault, as liberty at stake demands substantial justice. Petitioners filed notice of appeal correctly; error in transmittal not their responsibility. Thus, CA Decision and Resolution vacated; records remanded to RTC for transmission to Sandiganbayan with dispatch. (7 sentences)
Main Doctrine
Under Section 4 of Presidential Decree No. 1606, as amended, the Sandiganbayan has exclusive appellate jurisdiction over Regional Trial Court decisions in Republic Act No. 3019 cases involving public officers not occupying Salary Grade 27 or higher positions. Even if records are erroneously transmitted to the Court of Appeals by the clerk of court, the Court of Appeals' rulings are void for lack of jurisdiction, and the accused cannot be prejudiced by such clerical error, as the duty to transmit to the proper appellate court rests with the clerk. The Supreme Court thus vacates the Court of Appeals' dispositions and orders remand to the trial court for transmission to the Sandiganbayan, prioritizing substantial justice and the accused's liberty.