G.R. No. L-13146 - Castillo vs. Samonte

Petitioner: Celia T. Layus, the duly elected Mayor of Claveria, Province of Cagayan, a fifth class municipality.
Respondents: Sandiganbayan and the People of the Philippines.

Layus was charged with estafa through falsification of public documents and violations of sections of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act).
The criminal case (Criminal Case No. 23583) stemmed from an Information filed on 19 February 1997 based on a complaint that also implicated her relatives.
A Joint Resolution issued on 21 November 1996 by the Graft Investigation Officer recommended filing an information against her for the first charge while dismissing others.

Layus received the Joint Resolution on 21 February 1997 and filed a motion for reconsideration on 7 March 1997, even though she was apparently unaware that an Information had already been filed (filed on 17 February 1997).
A warrant of arrest was served on 8 April 1997, prompting her to post a cash bond for temporary liberty and file a motion to lift an imposed travel ban, as she was scheduled to travel abroad between 21 April and 15 May 1997.
During a hearing on 18 April 1997 regarding lifting the travel restriction, the Sandiganbayan required her to enter a plea; she pleaded not guilty on the condition that doing so would not be construed as a waiver of her right to file motions for reinvestigation and for quashing the Information.

On 24 March 1997, the Office of the Deputy Ombudsman denied her motion for reconsideration of the earlier Joint Resolution.
At the start of trial on 6 August 1997, Layus informed the court of a previously filed motion for reinvestigation (allegedly sent via registered mail) which the court had not received.
On 7 August 1997, she subsequently filed a motion to quash the Information.
An omnibus motion reiterating her right to reinvestigation was served and filed on 25 September 1997, but the Sandiganbayan denied this motion in its 1 December 1997 resolution and later also denied her motion to reconsider the denial.
On 19 November 1997, the prosecution filed a Motion to Suspend Accused Pendente Lite, which Layus opposed on 26 November 1997.
In light of the May 1998 elections and provisions under the Omnibus Election Code, the resolution on the suspension motion was delayed until 26 June 1998, when the Sandiganbayan granted the motion, imposing a 90-day suspension pendente lite.

The alleged error in the Sandiganbayan’s assumption of jurisdiction over her case on the basis that as a municipal mayor earning a salary classified as Salary Grade (SG) 25, she falls outside the ambit of officials (SG 27 and above) over which the Sandiganbayan has jurisdiction.
The error in denying her motion for reinvestigation, which she argued involved confidential fund matters governed by COA Circular No. 385, unauthenticated documentary evidence, and an alleged breach of procedural agreement regarding the suspension of the reglementary period.
The error in imposing a 90-day suspension pendente lite, citing a similar case (Rios v. Sandiganbayan) where a reduction to 60 days was ruled appropriate.

Whether the Sandiganbayan properly assumed jurisdiction over the petitioner's case despite her claim of receiving a salary classified as SG 25, contrary to the judicial threshold (SG 27) for municipal mayors.

Whether the denial of Layus’ motions for reinvestigation and reconsideration violated her right to due process, particularly in light of the alleged irregularities related to COA reports and unauthenticated evidence.

Whether the imposition of a 90-day preventive suspension was appropriate under Section 13 of R.A. No. 3019, or if it should have been reduced (as argued by the petitioner citing precedential cases).