G.R. No. 128055 - Defensor-Santiago vs. Sandiganbayan

Melanio Del Castillo and Sandra Bernales (private respondents), and Atty. Pablo B. Francisco (petitioner), are members of the Board of Brookside Residents Association, Inc. (BRAI).
On September 3, 2014, petitioner requested to inspect and obtain copies of the financial books and records of BRAI for the years 2008 to 2013.
The private respondents denied the request, prompting petitioner to file a criminal case for violation of Section 7(b) of Republic Act No. 9904 (R.A. No. 9904).

Private respondents were charged before the Regional Trial Court (RTC) of Antipolo City, Criminal Case No. 15-50102, with failure to provide copies of the financial records, violating the petitioner’s rights as a homeowner/member of BRAI.
The RTC issued a warrant of arrest; however, private respondents posted bail and were released pending trial.
Private respondents filed an Omnibus Motion to Quash the Information, the Warrant of Arrest, and To Cancel the Arraignment, arguing that the Housing and Land Use Regulatory Board (HLURB), not the regular court, had jurisdiction over violations of R.A. No. 9904.

On February 26, 2016, the RTC denied the Omnibus Motion to Quash, ordering the case to proceed.
A Motion for Reconsideration by private respondents was also denied on September 21, 2016.

Private respondents elevated the case to the CA via petition for certiorari.
On July 31, 2017, the CA reversed the RTC’s order, ruling that the HLURB has exclusive jurisdiction over such intra-association disputes, and that the alleged violation was not a criminal offense under the Revised Penal Code or other penal laws.
The CA granted the Omnibus Motion to Quash and ordered dismissal of the criminal case.
The petitioner’s motion for reconsideration was denied by the CA in a January 8, 2018 Resolution.

Petitioner filed a Petition for Review on Certiorari before the Supreme Court, seeking reversal of the CA’s Decision and Resolution and requesting the case be remanded to the RTC.
Private respondents and the Republic of the Philippines (through the Office of the Solicitor General) submitted comments supporting the CA’s ruling that the RTC lacks jurisdiction.
Petitioner reasserted that the case is criminal in nature and properly within RTC jurisdiction.

Whether the HLURB or the RTC has jurisdiction over the dispute concerning the alleged violation of R.A. No. 9904 regarding inspection of homeowner association records.
Whether the penalty provisions in Section 23, in relation to Sections 7(b) and 22(c) of R.A. No. 9904, constitute penal provisions that grant the RTC jurisdiction to hear and decide the case.