Case Digest (G.R. No. 174670)
Facts:
In COMELEC v. Judge Tomas B. Noynay (G.R. No. 132365, July 9, 1998), the Commission on Elections (COMELEC), through Minute Resolution No. 96-3076 dated October 29, 1996, authorized its Region VIII Director to file nine criminal informations under Section 261(i) of the Omnibus Election Code against private respondents Diosdada F. Amor, Esbel Chua, and Ruben Magluyoan—public school personnel accused of engaging in partisan political activities. These informations were docketed as Criminal Cases Nos. A-1439 to A-1449 before Branch 23 of the Regional Trial Court (RTC) in Allen, Northern Samar. On August 25, 1997, Acting Presiding Judge Tomas B. Noynay issued an order motu proprio withdrawing the records and directing the COMELEC Law Department to refile in the Municipal Trial Court (MTC), invoking Section 32 of B.P. Blg. 129, as amended by R.A. No. 7691, on the ground that the maximum penalty of six years placed the offenses within MTC jurisdiction. After denyingCase Digest (G.R. No. 174670)
Facts:
- Nature and Background of the Case
- The Commission on Elections (COMELEC) filed a special civil action for certiorari with mandamus challenging the Regional Trial Court’s (RTC) withdrawal of election offense cases.
- The pivotal issue was whether Republic Act No. 7691 (RA 7691) divested RTCs of jurisdiction over election offenses punishable by imprisonment not exceeding six years.
- Proceedings in the Regional Trial Court
- In Minute Resolution No. 96-3076 (29 October 1996), COMELEC authorized prosecution of respondents Diosdada Amor, Esbel Chua, and Ruben Magluyoan for violation of Section 261(i) of the Omnibus Election Code (OEC) (partisan political activity by public officers/teachers).
- Nine informations (Criminal Cases Nos. A-1439 to A-1449) were filed with RTC Branch 23, Allen, Northern Samar.
- On 25 August 1997, Judge Tomas B. Noynay motu proprio withdrew the records and ordered referral to the Municipal Trial Court (MTC), citing Section 32 of B.P. Blg. 129 as amended by RA 7691 (MTC jurisdiction over offenses punishable by ≤6 years).
- COMELEC’s motions for reconsideration were denied on 17 October 1997.
- Petition to the Supreme Court
- COMELEC petitioned for certiorari and mandamus, arguing that Section 268 of the OEC vests exclusive original jurisdiction over election offenses in the RTC.
- The Office of the Solicitor General adopted the petition; private respondents contended RA 7691 conferred exclusive jurisdiction on MTCs for offenses with maximum penalty of six years.
Issues:
- Whether RA 7691 divested Regional Trial Courts of jurisdiction over election offenses punishable by imprisonment not exceeding six years, thereby granting exclusive original jurisdiction to Municipal Trial Courts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)