Case Digest (G.R. No. L-50581-50617)
Facts:
Rufino v. Nunez, G.R. Nos. 50581-50617, January 30, 1982, Supreme Court En Banc, Fernando, C.J., writing for the Court. Petitioner Rufino was indicted before the Sandiganbayan for estafa through falsification of public and commercial documents, allegedly committed in connivance with other public officials in multiple separate cases; the informations were filed on February 21 and March 26, 1979. Upon arraignment on May 15, 1979, Rufino moved to quash the informations on constitutional and jurisdictional grounds; the Sandiganbayan denied the motion and subsequently denied reconsideration.Rufino then filed a petition for certiorari and prohibition in the Supreme Court (a certiorari and prohibition proceeding) assailing the validity of Presidential Decree No. 1486, as amended by Presidential Decree No. 1606 (both 1978), which created and later amended the charter and procedures of the Sandiganbayan. He argued that the Decrees violated the Due Process, Equal Protection and Ex Post Facto provisions of the Constitution. The Solicitor General filed an exhaustive memorandum defending the Decrees; counsel for petitioner and the Solicitor General (assisted by named assistants) were noted in the record.
The Supreme Court considered the historic and statutory background—earlier anti-graft legislation (e.g., R.A. No. 1379, R.A. No. 3019) and prior jurisprudence (notably Morfe v. Mutuc)—and analyzed whether the creation and procedural regime of the Sandiganbayan impermissibly abridged constitutional protections of accused persons. The Court ultimate...(Pro-only)
Issues:
- Does Presidential Decree No. 1486 as amended by Presidential Decree No. 1606 violate the Due Process Clause of the Constitution?
- Does the Decree violate the Equal Protection Clause by limiting appellate review of Sandiganbayan convictions to certiorari before the Supreme Court and omitting intermediate review by the Court of Appeals?
- Does the Decree operate as an ex post facto law by altering appellate procedure to the detriment of persons accused of o...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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