G.R. No. 218390 - Hongkong Bank Independent Labor Union vs. Hongkong and Shanghai Banking Corp. Limited

The case is a special civil action for certiorari with preliminary injunction, assailing the resolutions of the Sandiganbayan, Fourth Division, which denied petitioner’s motion to quash the information for lack of merit.
The petitioner, Lilia B. Organo, challenged the jurisdiction of the Sandiganbayan on the ground that, after the enactment of Republic Act No. 8249, the court would no longer have jurisdiction over the case.

On August 15, 1997, Special Prosecution Officer Jose T. de Jesus, Jr. filed an Information against petitioner, among others, for the crime of plunder as defined under Republic Act No. 7080 (as amended by Republic Act No. 7659).
The Information alleged that on or about November 5, 1996 (or sometime prior or subsequent thereto), in Quezon City, the accused—public officers then working at the Bureau of Internal Revenue—conspired to amass and acquire public funds by:

Opening an unauthorized bank account at the Landbank of the Philippines, West Triangle Branch, Diliman, Quezon City, on behalf of the Bureau of Internal Revenue;
Depositing money comprising government revenue tax payments; and
Withdrawing a total amount of ₱193,565,079.64 (Philippine Currency) between November 1996 and February 1997 through checks payable to themselves and/or their sole proprietorship firms, resulting in misappropriation, conversion, misuse, and/or malversation of public funds.

On August 20, 1997, petitioner filed a motion to quash the Information on the ground that the Sandiganbayan lacked jurisdiction under the provisions of Republic Act No. 8249, which was approved on February 5, 1997.
Despite the pending motion, on September 29, 1997, the Sandiganbayan issued a warrant of arrest against all accused without first resolving the jurisdictional issue.
On November 28, 1997, the Sandiganbayan denied petitioner’s motion to quash the Information for lack of merit.
On December 9, 1997, petitioner filed a motion for reconsideration, again arguing lack of jurisdiction in view of Republic Act No. 8249.
On April 28, 1998, after 140 days from the filing of the motion for reconsideration, the Sandiganbayan issued a resolution denying the motion and ruled that petitioner should first surrender to the court before filing further pleadings, prompting this petition.

On June 23, 1998, the Court directed the respondents to comment on the petition within ten (10) days.
The Office of the Special Prosecutor, representing the People of the Philippines, filed its comment on September 14, 1998, and the Solicitor General filed his comment on January 4, 1999.

The central issue involves whether, at the time of the filing of the Information, the Sandiganbayan had jurisdiction over the case given the enactment of Republic Act No. 8249 on February 5, 1997, which limits its jurisdiction to offenses committed by public officers and employees occupying positions with Salary Grade “27” or higher.
Petitioner contended that since none of the accused held positions falling within the Salary Grade “27” or higher, the jurisdiction should have belonged to the Regional Trial Court.
The respondent Sandiganbayan, on the other hand, maintained that Republic Act No. 7080 (a special law on plunder) automatically vested jurisdiction in the Sandiganbayan, notwithstanding the provisions of Republic Act No. 8249.

Whether the Sandiganbayan had jurisdiction over the case at the time of the filing of the Information on August 15, 1997, given the enactment of Republic Act No. 8249.

Sub-issue: Whether the special law (Republic Act No. 7080, as amended by Republic Act No. 7659) prevails over the general jurisdictional scheme provided by Republic Act No. 8249.
Sub-issue: Whether the absence of accused officials holding positions with Salary Grade “27” or higher should have diverted jurisdiction from the Sandiganbayan to the Regional Trial Court.

Whether the procedural actions taken by the Sandiganbayan, including the issuance of a warrant of arrest and resolutions denying the motions to quash and for reconsideration, were valid given the alleged jurisdictional error.