G.R. No. 134102 - Abbot vs. Mapayo

Petitioner Teodoto B. Abbot, Chief of the Irrigation System for the Mal-River Project under the National Irrigation Administration in Manga, Matanao, Davao del Sur, was charged with malversation through the falsification of a public document.
It was alleged that Abbot falsified the Viability Incentive Grant payroll so that the compensation for seven complaining witnesses was misrepresented: while the document purported that each witness received P4,500.00, in fact, four witnesses received only P1,500.00 each and three received P2,000.00 each.
By creating this discrepancy, Abbot allegedly misappropriated a total of P19,500.00 for his personal use.

The case was initially filed before the Sandiganbayan, but later transferred to the Regional Trial Court (RTC) pursuant to Republic Act No. 7975.
At arraignment in the RTC, Abbot pleaded not guilty and subsequently filed an omnibus motion for dismissal, contending that the funds in question had ceased to be part of the public fund due to the endorsement and subsequent encashment of the check by him.
The RTC, Branch 19 in Digos, Davao del Sur, denied his omnibus motion on October 29, 1996, and again on February 12, 1997, when his motion for reconsideration was also denied.

Dissatisfied with the RTC’s decisions, Abbot assailed the orders before the Court of Appeals by filing a Petition for Certiorari with Prohibition.
He argued that the trial court gravely abused its discretion by not dismissing the information on the ground that the facts admitted were insufficient to constitute an offense, further supported by a stipulation of facts already made during pre-trial.
The Office of the Solicitor General, along with the Court of Appeals, maintained that the petition for certiorari with prohibition fell under the exclusive jurisdiction of the Sandiganbayan rather than the Court of Appeals.

The central issue revolved around which tribunal – the Sandiganbayan or the Court of Appeals – had jurisdiction to entertain the petitioner’s extraordinary writ.
Relevant statutes and laws, notably Presidential Decree No. 1606 and Republic Act No. 7975, were scrutinized to delineate the jurisdiction of the Sandiganbayan, especially its power over petitions for writs of certiorari, prohibition, mandamus, and related ancillary remedies.
The case was further complicated by contrasting interpretations from Garcia, Jr. v. Sandiganbayan which initially limited the Sandiganbayan’s jurisdiction but was later superseded by RA 7975, expanding its jurisdiction.

Which tribunal has jurisdiction over a Petition for Certiorari with Prohibition filed in relation to the decision of a Regional Trial Court?

Does the Court of Appeals have jurisdiction or is the petition exclusively within the jurisdiction of the Sandiganbayan?

Whether the trial court committed a grave abuse of discretion by failing to dismiss the information against petitioner based on the alleged insufficiency of the facts to constitute an offense.