Case Digest (G.R. No. L-50581-50617)
Facts:
In Rufino v. Nunez (G.R. Nos. 50581-50617, Jan. 30, 1982), petitioner Rufino—a private citizen—was charged before the Sandiganbayan with estafa and falsification of public and commercial documents in collusion with other public officials. These informations were filed on February 21 and March 26, 1979. Upon arraignment on May 15, 1979, Rufino filed a motion to quash, arguing that Presidential Decree No. 1486, as amended by P.D. 1606 (both issued in 1978), was unconstitutional under the 1973 Constitution’s due process, equal protection, and ex post facto clauses. The Sandiganbayan denied the motion and a subsequent motion for reconsideration, prompting Rufino to seek certiorari and prohibition relief from the Supreme Court.Issues:
- Does the creation of the Sandiganbayan by P.D. 1486 (as amended by P.D. 1606) violate the due process guarantee of the 1973 Constitution?
- Does the Decree offend the equal protection clause by subjecting only graft-and-corruption cases to special ru
Case Digest (G.R. No. L-50581-50617)
Facts:
- Constitutional and statutory framework
- Article XIII, Section 5 of the 1973 Constitution provided for the creation of a special court—the Sandiganbayan—with jurisdiction over graft, corrupt practices, and related offenses by public officers and employees.
- In 1978, Presidential Decree No. 1486, as amended by Presidential Decree No. 1606, formally established the Sandiganbayan.
- Under the 1935 Constitution, anti-graft legislation began with Republic Act No. 1379 (1955) and was supplemented by R.A. 3019 (1960); Morfe v. Mutuc (1968) upheld the latter’s validity.
- Proceedings below
- Petitioner Rufino was charged before the Sandiganbayan with estafa through falsification of public and commercial documents filed in February–March 1979.
- Upon arraignment (May 15, 1979), he moved to quash the informations on grounds that P.D. 1486/1606 violated due process, equal protection, and ex post facto clauses.
- The Sandiganbayan denied the motion and its reconsideration; Rufino then filed a petition for certiorari and prohibition with the Supreme Court.
Issues:
- Jurisdictional authority
- Did the President have constitutional power to create the Sandiganbayan by P.D. 1486/1606 under the 1973 Constitution and 1976 amendments?
- Due process
- Do the Sandiganbayan’s procedures deprive the accused of due process of law?
- Equal protection
- Does limiting appeals from Sandiganbayan convictions to questions of law by certiorari, with no factual review and only one appellate remedy, violate equal protection compared to ordinary estafa cases?
- Ex post facto
- Does applying Sandiganbayan procedure to offenses committed before its creation contravene the ex post facto clause?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)