Case Digest (G.R. No. 133535)
Facts:
Lilia B. Organo filed a petition for certiorari challenging resolutions of the Sandiganbayan, Fourth Division, that denied her motion to quash an Information for lack of jurisdiction and later required her to first surrender before filing further pleadings. On August 15, 1997 the Office of the Special Prosecutor filed an Information for the crime of plunder under R.A. No. 7080, as amended, and petitioner moved to quash on August 20, 1997; the Sandiganbayan denied the motion on November 28, 1997 and denied reconsideration on April 28, 1998.
Issues:
- Did the Sandiganbayan have jurisdiction over the plunder case after the enactment of Republic Act No. 8249?
- Was the Sandiganbayan correct in requiring petitioner to surrender before filing further pleadings?
Ruling:
The Court granted the petition and annulled the Sandiganbayan resolutions dated November 28, 1997 and April 28, 1998. The Court ordered the Sandiganbayan to refer the case forthwith to the court of proper jurisdiction and imposed no costs.
Ratio:
The Court held that R.A. No. 8249, enacted February 5, 1997, redefined the Sandiganbayan’s original jurisdiction to cases involving public officials occupying positions with Salary Grade "27" or higher; earlier provisos in R.A. No. 7080 placing plunder within the Sandiganbayan applied until otherwise provided by law and were superseded by R.A. No. 8249. Because none of the accused occupied positions of Salary Grade 27 or higher, the Sandiganbayan lacked jurisdiction and committed a grave error warranting annulment and referral.
Doctrine:
- Republic Act No. 8249 limits the Sandiganbayan’s exclusive original jurisdiction to cases where the accused hold positions corresponding to Salary Grade 27 or higher.
- (Get Pro to unlock 2 more doctrines)