Title
Alvia vs. Sandiganbayan
Case
G.R. No. L-51923-25
Decision Date
Jun 19, 1985
Alicia Alvia, charged with qualified theft at PNB, contested Sandiganbayan's jurisdiction over her cases. SC upheld Sandiganbayan's authority, ruling transfer proper under PD 1606, denying her motion for remand.
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Case Digest (G.R. No. L-51923-25)

Facts:

Background of the Case:
Petitioner Alicia V. Alvia was charged with 118 counts of qualified theft in connection with her employment at the Philippine National Bank, a government-owned and controlled corporation. The cases were filed in different branches of the then Court of First Instance of Lanao del Norte and the City Court of Iligan City.

Progress of the Cases:

  • In Branch I of the Court of First Instance, petitioner was arraigned, and the trial commenced.
  • In the City Court, petitioner was also arraigned, and the cases were jointly tried and partially heard.
  • In 79 cases filed in Branches II and III of the Court of First Instance, petitioner had not yet been arraigned. These cases were transferred to the Sandiganbayan upon motion of the City Fiscal and were docketed as Criminal Cases Nos. 268-302 and 377-420.

Petitioner's Motion:
Petitioner filed a motion before the Sandiganbayan to return the cases to the Court of First Instance (now Regional Trial Court) of Lanao del Norte. The motion was denied, and petitioner was arraigned in the Sandiganbayan.

Temporary Restraining Order:
On November 22, 1979, the Supreme Court issued a temporary restraining order, halting further proceedings in the Sandiganbayan.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction of the Sandiganbayan:

    • Section 4 of Presidential Decree No. 1606 explicitly grants the Sandiganbayan jurisdiction over crimes committed by public officers, including those in government-owned or controlled corporations.
    • Section 8 of the same decree mandates the transfer of cases to the Sandiganbayan if the accused has not yet been arraigned. Since petitioner had not been arraigned in the Court of First Instance, the transfer was proper.
  2. Ex-Post Facto Argument:

    • Presidential Decree No. 1606 is not a penal statute but a procedural one. It does not violate the constitutional prohibition against ex-post facto laws.
  3. Right to Appeal:

    • The petitioner's right to appeal is not diminished. The Sandiganbayan's decision can still be reviewed by the Supreme Court for errors of law. The constitutional presumption of innocence is safeguarded, and the Court ensures that moral certainty is achieved in criminal convictions.
  4. Inconvenience Argument:

    • The inconvenience of holding the trial in Manila is not a valid reason to remand the cases to the Court of First Instance.

Dissenting Opinion (Justice Teehankee):
Justice Teehankee dissented, arguing that the cases should have remained with the Court of First Instance, as the transfer to the Sandiganbayan violated due process and the guarantee against ex-post facto laws. He emphasized that the right to appeal to two appellate tribunals (Court of Appeals and Supreme Court) was already secured under existing laws and was part of procedural due process.


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