G.R. No. 242670 - Commissioner of Internal Revenue vs. McDonald's Philippines Realty Corp.

The case involves a petition for habeas corpus filed under Rule 102 of the Rules of Court by Fleurdeliz B. Organo on behalf of her mother, Lilia B. Organo, who was in custody.
The petition was prompted by the issuance of a warrant of arrest by the Sandiganbayan in Criminal Case No. 24100, which charged several public officials with the crime of plunder under Republic Act (RA) No. 7080.

In an Information filed on August 15, 1997, seven public officials—including Dominga S. Manalili, Teofisto A. Sapitula, Joel DP. Marcelo, Lilia B. Organo, Gil R. Erencio, Reynaldo S. Enriquez, and Luis S. Se, Jr.—were accused of misappropriating public funds.
The Information alleged that on or about November 5, 1996 (as well as around that period), the accused, while serving as public officers of the Bureau of Internal Revenue, had unlawfully opened an unauthorized bank account at the Landbank of the Philippines. Funds amounting to over P193 million were withdrawn through checks payable to themselves or their private firms, thereby constituting an act tantamount to a raid on the public treasury.

The Information was raffled to the First Division of the Sandiganbayan, and subsequently, the case was unloaded to the 4th Division with the creation of additional divisions.
On August 20, 1997, Lilia B. Organo filed a Motion to Quash the Information on the ground of lack of jurisdiction and to defer the issuance of an arrest warrant.
Despite her prayer and later filing an Urgent Motion to Recall and/or Quash the warrant of arrest on October 1, 1997, the respondent court, on November 20, 1997, denied her motion.
Organo then filed a Motion for Reconsideration on December 9, 1997, which was later denied on April 28, 1998, with the court emphasizing that she was still a fugitive and was not yet under its jurisdiction.
Concurrently, and in an effort to secure her release, a separate petition for certiorari and prohibition under Rule 65 was filed before the Supreme Court concerning the same jurisdictional issue.

The central issue arose over whether the Sandiganbayan had jurisdiction to try cases of plunder when the accused public officials did not occupy positions corresponding to Salary Grade 27 or higher, as mandated by RA 8249.
The dispute centered on the interpretation of RA 7080 and RA 8249, with the latter confining the Sandiganbayan’s jurisdiction to cases involving higher-ranking officials, hence potentially impliedly repealing parts of RA 7080 regarding plunder prosecutions.

Following the issuance of the arrest warrant, Lilia B. Organo was apprehended and detained by the National Bureau of Investigation, and later transferred to the Manila City Jail.
The petition for habeas corpus sought an immediate release of Organo, on the basis that the warrant was improperly issued by a court lacking jurisdiction according to the statutory criteria established by RA 8249.

Does the Sandiganbayan, under the ambit of RA 8249, have jurisdiction over a plunder case when none of the accused, including Lilia B. Organo, occupies a position corresponding to Salary Grade 27 or higher?

How do the provisions of RA 7080, which initially placed plunder cases within the Sandiganbayan’s jurisdiction, reconcile with the amendments under RA 8249 that impose a salary grade requirement for jurisdiction?