Case Digest (G.R. No. 120681-83)
Facts:
Jejomar C. Binay v. Hon. Sandiganbayan (Third Division) and the Department of Interior and Local Government, G.R. Nos. 120681-83, and Mario C. Magsaysay, et al. v. Hon. Sandiganbayan, Hon. Ombudsman, G.R. No. 128136, October 01, 1999, Supreme Court En Banc, Kapunan, J., writing for the Court.In G.R. Nos. 120681-83, the Office of the Ombudsman filed three informations on September 7, 1994 (amended September 15, 1994) against Jejomar C. Binay, then Mayor of Makati (when it was still a municipality), charging one count under Article 220, Revised Penal Code, and two counts under Section 3(e), R.A. No. 3019. Binay moved to quash, arguing delay in the filing of informations before the Sandiganbayan violated due process; the Sandiganbayan denied the motion to quash (March 29, 1995) and denied reconsideration. After the prosecution moved for and obtained Binay’s suspension pendente lite (April 25, 1995), Binay filed petitions in this Court seeking certiorari, prohibition and mandamus to set aside the Sandiganbayan resolutions; the Court on July 7, 1995 issued a temporary restraining order preventing suspension and arraignment. On June 13, 1995 Binay moved in the Sandiganbayan to refer his cases to the RTC under R.A. No. 7975; the Sandiganbayan denied the motion on July 4, 1995. Binay then filed the present petition before the Supreme Court (July 7, 1995).
In G.R. No. 128136, Mario C. Magsaysay and several municipal officials of San Pascual, Batangas faced informations alleging violations of Section 3(e) and (g), R.A. No. 3019. One information was filed in the RTC of Batangas on August 11, 1995; another, covering substantially the same facts, was later filed in the Sandiganbayan (Crim. Case No. 22378) on February 9, 1996. The Sandiganbayan initially denied a motion to quash (June 21, 1996) but stayed proceedings pending resolution of the Binay jurisdiction question; after motions and reconsiderations the Sandiganbayan, on October 22, 1996, reversed and set the case for arraignment. The accused filed the present petition on February 27, 1997; the Court issued a temporary restraining order on October 1, 1997 to enjoin further proceedings in Sandiganbayan Crim. Case No. 23278. The two matters were consolidated by the Court on October 6, 1997. The petitions raised jurisdictional questions under Presidential Decree No. 1606 (as amended), R.A. No. 7975 a...(Pro-only)
Issues:
- Under R.A. No. 7975 (and later R.A. No. 8249) did the Sandiganbayan retain exclusive original jurisdiction over criminal cases involving municipal mayors charged with violations of R.A. No. 3019 and Article 220, Revised Penal Code?
- Was petitioner Binay deprived of his constitutional right to a speedy disposition of cases by the Ombudsman’s delay and, relatedly, was his suspension pendente lite unwarranted?
- In the Magsaysay matter, did the filing of an information in the RTC oust the Sandiganbayan’s jurisdiction, and are the Ombudsman/prosecutors estopped by laches or waiver from filing in the Sandiganbayan?
- Did the filing of two informations (one in the RTC, one in the Sandiganbayan) create duplicity or subject petitioners to double...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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