Case Digest (G.R. No. 128096)
Facts:
Panfilo M. Lacson v. The Executive Secretary, The Sandiganbayan, Office of the Special Prosecutor, The Department of Justice, Myrna Abalora, Nenita Alap-ap, Imelda Pancho Montero, and The People of the Philippines, G.R. No. 128096, January 20, 1999, Supreme Court En Banc, Austria‑Martinez, J., writing for the Court.Petitioner Panfilo M. Lacson (joined by intervenors Romeo M. Acop and Francisco G. Zubia, Jr.) challenged Sections 4 and 7 of Republic Act No. 8249 and sought to prevent the Sandiganbayan from proceeding with Criminal Cases Nos. 23047–23057 (multiple murder) on the ground that the Sandiganbayan lacked jurisdiction.
On May 18, 1995, eleven persons, allegedly members of the Kuratong Baleleng gang, were killed along Commonwealth Avenue by elements of an Anti‑Bank Robbery and Intelligence Task Group (ABRITG) composed of various PNP units. A media expose prompted an Ombudsman inquiry; an initial investigative panel cleared the implicated PNP personnel, but a subsequent review recommended indictment. The Ombudsman approved the recommendation (with one withdrawal), and on November 2, 1995 petitions were filed in the Sandiganbayan charging Lacson as principal in eleven murder informations; Acop and Zubia were later charged in the same informations as accessories after the fact.
Following a permitted motion for reconsideration, the Ombudsman filed eleven amended informations on March 1, 1996 in which Lacson and the intervenors were charged only as accessories; one accused was dropped. The accused filed separate motions contesting Sandiganbayan jurisdiction, invoking R.A. No. 7975 which limited Sandiganbayan original jurisdiction to cases where one or more of the principal accused were officials of specified ranks (e.g., Salary Grade 27 or PNP Chief Superintendent).
On May 8, 1996, the Sandiganbayan Second Division (Demetriou, with Lagman and de Leon concurring; Balajadia and Garchitorena dissenting) admitted the amended informations and ordered transfer to the Quezon City Regional Trial Court (RTC) under R.A. 7975. The Office of the Special Prosecutor moved for reconsideration. While that motion was pending, Congress consolidated bills that deleted the word “principal” from R.A. 7975’s jurisdictional language and approved them as R.A. No. 8249 (approved February 5, 1997; stated effective February 25, 1997).
On March 5, 1997 the Sandiganbayan denied reconsideration but issued an addendum stating that, in light of R.A. 8249, a majority now favored retaining jurisdiction because three accused (Canson, Acop, Lacson) were PNP Chief Superintendents; the net result was that by vote the court admitted the amended informations and—by a separate tally—retained jurisdiction. Petitioners then sought prohibition and mandamus from the Supreme Court, challenging the constitutionality and retroactive application of Sections 4 and 7 of R.A. 8249 (claiming bad faith, class legislation, ex post facto effect, denial of procedural due process and equal protection, and violation of the one‑title‑one‑subject rule). Th...(Pro-only)
Issues:
- Are Sections 4 and 7 of Republic Act No. 8249 unconstitutional on grounds of bad faith/class legislation, denial of procedural due process/equal protection, ex post facto application, or violation of the one‑title‑one‑subject rule?
- Does Section 7 of R.A. No. 8249 apply to pending cases and thereby retroactively affect petitioners’ cases?
- Do the amended informations in Criminal Cases Nos. 23047–23057 sufficiently allege that the murders were committed “in relation to” the accuseds’ official functions so as to confer exclusive original jurisdiction upon t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)