Facts:

• The case "Binay v. Sandiganbayan" involves two consolidated petitions questioning the Sandiganbayan's jurisdiction over criminal cases against municipal mayors for violations of the Anti-Graft and Corrupt Practices Act.
• Jejomar Binay, then Mayor of Makati, filed the first petition (G.R. Nos. 120681-83) to annul the Sandiganbayan's resolution denying his motion to refer his cases to the RTC of Makati. Binay faced charges of illegal use of public funds and two counts of violating Section 3(e) of R.A. No. 3019.
• Mario C. Magsaysay, Mayor of San Pascual, Batangas, and other municipal officials filed the second petition (G.R. No. 128136) challenging the Sandiganbayan's resolution reversing its earlier order to suspend proceedings in their case. They were charged with overpaying for a landscaping project.
• Binay argued that the six-year delay in filing the charges violated his right to due process. The Sandiganbayan denied his motion to quash and ordered his suspension pendente lite.
• R.A. No. 7975, redefining the jurisdiction of the Sandiganbayan, took effect on May 16, 1995.
• The Sandiganbayan ruled it had jurisdiction over the cases, leading to the consolidated petitions before the Supreme Court.

Issue:

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Ruling:

1. The Supreme Court ruled that the Sandiganbayan has exclusive original jurisdiction over the cases involving municipal mayors.
2. The Court found no violation of the petitioners' right to a speedy disposition of cases.
3. The respondents are not estopped from filing an information before the Sandiganbayan.
4. The filing of the information in the Sandiganbayan d...(Unlock)

Ratio:

1. Municipal mayors are classified under Salary Grade 27 according to both the 1989 and 1997 versions of the Index of Occupational Services, Position Titles, and Salary Grades. Therefore, they fall under the exclusive original jurisdiction of the Sandiganbayan as per Section 4a(1) of P.D. No. 1606, as amended by R.A. No. 7975 and R.A. No. 8249. The phrase "specifically including" in the law indicates non-exclusivity of the enumeration, and the principle of expressio unius est exclusio alterius does not apply.
2. The delay in the resolution of the cases was justified due to the complexity of the issues and the need for the prosecution to conduct its own review of the COA findings. The right to a speedy disposition of cases is a relative term and must be assessed based on the facts and circumstances of each case.
3. Jurisdiction is determined by law, not by the consent or agreem...continue reading