Case Digest (G.R. No. 146646-49) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rogelio M. Esteban v. Sandiganbayan and the People of the Philippines (G.R. Nos. 146646–49, decided June 5, 2006), petitioner Judge Rogelio M. Esteban, then Presiding Judge of the Municipal Trial Court in Cities (MTCC) Branch 1, Cabanatuan City, was accused by his subordinate, Ana May V. Simbajon, of committing acts of lasciviousness in his chambers. Simbajon, a casual employee of the City Government detailed to Branch 1, applied for a permanent bookbinder position that became vacant. Between February and August 1997, petitioner allegedly conditioned his endorsement of her appointment on her agreement to be his “girlfriend” and give him daily kisses. After she refused, he forcibly kissed her on the cheek and later embraced and kissed her all over the face while touching her breast. Simbajon lodged a sworn complaint with the Cabanatuan City Prosecutor on September 8, 1997 for sexual harassment. In 1998, the Sandiganbayan received Informations for violation of R.A. 7877 (the An Case Digest (G.R. No. 146646-49) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Complaint
- Ana May V. Simbajon, a casual employee of Cabanatuan City, was detailed to MTCC Branch 1 upon repeated requests of Presiding Judge Rogelio M. Esteban. When she applied for a vacant bookbinder position, Esteban delayed action on her application.
- On July 25, 1997, Esteban demanded that she become his “girlfriend” and kiss him daily in exchange for signing her appointment. He then kissed her on the left cheek without consent, prompting her to leave in shock.
- Subsequent Incident and Filing of Cases
- On August 5, 1997, Esteban again summoned Simbajon, insisted she report daily as his “girlfriend,” forcibly kissed her all over the face, and touched her right breast. She escaped and confided in a co-employee.
- Informations were filed on March 9 and July 1, 1998 for violation of R.A. 7877 (Anti-Sexual Harassment Law) and for acts of lasciviousness before the Sandiganbayan (Criminal Cases Nos. 24490, 24702, 24703, 24704).
- Motions to Quash and Amendments
- Esteban moved to quash the original Informations for double jeopardy and lack of jurisdiction; the Sandiganbayan denied relief but directed the prosecution to allege connection to office.
- On September 3, 1999, the prosecution filed Amended Informations in Nos. 24703-04, alleging that the acts of lasciviousness were committed in relation to Esteban’s official function of recommending Simbajon’s appointment.
- Esteban’s motion to quash for lack of jurisdiction was denied by Resolution dated December 18, 2000, and Reconsideration Motion by Order of January 11, 2001.
- Petition to the Supreme Court
- Esteban filed a petition for certiorari under Rule 65 seeking to annul the Sandiganbayan’s orders, contending the acts were not related to his official duties and thus beyond the court’s jurisdiction.
- The Office of the Special Prosecutor maintained that the Informations adequately alleged an intimate relation between the offenses and Esteban’s appointment power as a judge.
Issues:
- Jurisdictional Question
- Whether the Sandiganbayan has exclusive original jurisdiction under Section 4(b) of PD 1606, as amended by R.A. 8249, over the acts of lasciviousness charged in Criminal Cases Nos. 24703-04, given their alleged connection to Esteban’s official functions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)