Case Digest (G.R. No. 161784-86)
Facts:
- Dinah C. Barriga is the petitioner against the Honorable Sandiganbayan (4th Division) and the People of the Philippines.
- The case originated on April 3, 2003, when the Office of the Ombudsman filed a motion with the Sandiganbayan for the admission of three Amended Informations.
- Criminal Case No. 27435 charged Barriga and Virginio E. Villamor, the Municipal Mayor of Carmen, Cebu, with malversation of public funds amounting to P23,047.20 for the Corte-Cantumog Water System Project.
- Criminal Case No. 27436 accused them of illegal use of public funds amounting to P1,305.00 for a project not included in the Central Visayas Water and Sanitation Project Trust Fund.
- Criminal Case No. 27437 similarly charged them with illegal use of public funds amounting to P267,537.96 for another project misaligned with the intended use of the funds.
- Barriga filed a Motion to Quash the Amended Informations, arguing that the Sandiganbayan lacked jurisdiction and that the prosecution failed to establish her role as an accountable officer.
- The Sandiganbayan denied her motion on October 9, 2003, prompting her to file a petition for certiorari under Rule 65 of the Rules of Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the petition has no merit and affirmed the Sandiganbayan's resolutions.
- The Court held that the Sandiganbayan has original jurisdiction over the crimes of malversation and illegal use of public funds as charged in the Amended Informations.
- The allegation...(Unlock)
Ratio:
- The Court's decision was based on Republic Act No. 8249, which grants the Sandiganbayan original jurisdiction over crimes committed by public officers.
- Malversation and illegal use of public funds are crimes where the public office held by the accused is integral to the commission of the offense.
- The mere allegation of the crimes being committed in relation to the office is sufficient for jurisdiction.
- Bar...continue reading
Case Digest (G.R. No. 161784-86)
Facts:
The case involves Dinah C. Barriga as the petitioner against the Honorable Sandiganbayan (4th Division) and the People of the Philippines as respondents. The events leading to this case began on April 3, 2003, when the Office of the Ombudsman filed a motion with the Sandiganbayan for the admission of three Amended Informations. The first Amended Information, docketed as Criminal Case No. 27435, charged Dinah C. Barriga, the Municipal Accountant, and Virginio E. Villamor, the Municipal Mayor of Carmen, Cebu, with malversation of public funds amounting to P23,047.20, intended for the Corte-Cantumog Water System Project. The second Amended Information, Criminal Case No. 27436, accused them of illegal use of public funds amounting to P1,305.00, which was misappropriated for a project not included in the Central Visayas Water and Sanitation Project Trust Fund. The third Amended Information, Criminal Case No. 27437, similarly charged them with illegal use of public funds amounting to P267,537.96 for a project that also did not align with the intended use of the funds.
Barriga filed a Motion to Quash the Amended Informations, arguing that the Sandiganbayan lacked jurisdiction over the crimes charged, as the allegations did not sufficiently demonstrate the connection between her official duties and the offenses. She contended that the prosecution failed to establish her role as an accountable officer and that the crimes charged were not included under the jurisdiction of the Sandiganbayan. The Sandiganbayan denied her motion on October 9, 2003, leading to...