G.R. No. 203697 - Interphil Laboratories, Inc. vs. OEP Philippines, Inc.

Section 46 of Republic Act No. 6975, an act establishing the Philippine National Police (PNP), provides that criminal cases involving PNP members shall be within the exclusive jurisdiction of the regular courts.
The principal issue arose from the interpretation of the term “regular courts” and whether it includes the Sandiganbayan, a court created to try certain offenses committed by public officers.
The legislative history shows that the term “regular courts” was used interchangeably with “civil courts” to divest courts-martial of jurisdiction over crimes by PNP members and transfer such jurisdiction to the civilian (regular) courts.

On July 31, 1991, Respondent Alexander Dionisio y Manio, a member of the PNP assigned to the Central Police District Command Station 2 in Quezon City, was dispatched to investigate a disturbance in Novaliches, where he shot T/Sgt. Romeo Sadang, resulting in the latter’s death.
On August 7, 1991, the Office of the City Prosecutor filed an information before the Regional Trial Court (RTC) of Quezon City, charging Dionisio with homicide.
The case was docketed as Criminal Case No. Q-91-23224 and assigned to Branch 104 of the RTC, presided over by the respondent Judge.

On September 4, 1992, while the trial was in progress, the respondent Judge issued a motion requiring the parties to comment on whether the court should continue with the trial in light of the Supreme Court’s decision in Deloso vs. Domingo.
On September 24, 1992, the respondent Judge dismissed the case “for re-filing with the Sandiganbayan,” based primarily on the argument that the penalty for homicide (reclusion temporal) made the case cognizable by the Sandiganbayan pursuant to P.D. No. 1606.
Petitioner subsequently filed a motion for reconsideration, arguing that crimes committed by PNP members, under Section 46 of R.A. No. 6975, fall within the exclusive jurisdiction of the regular (civil) courts and not the Sandiganbayan.
The respondent Judge denied the motion on October 7, 1992, maintaining that the term “regular courts” in Section 46 inclusively covers the Sandiganbayan, which is part of the judicial system.
On January 6, 1993, the petitioner filed the instant petition challenging the dismissal of Criminal Case No. Q-91-23224.
The Office of the Ombudsman intervened on February 5, 1993, asserting that it has primary jurisdiction to investigate crimes committed by public officers, including PNP members, and supporting the transfer of jurisdiction to the Sandiganbayan based on joint circular guidelines and statutory interpretation.

Argued that Section 46 of R.A. No. 6975 only vests jurisdiction in the “regular courts” which, in its view, excludes the Sandiganbayan because the latter is a “special court” by virtue of its constitutional and statutory mandate.
Pointed to constitutional provisions and legislative history indicating that if the Sandiganbayan were intended to have jurisdiction, the law should have used explicit terminology such as “civil courts.”
Asserted that there exists an irreconcilable conflict between Section 46 of R.A. No. 6975 and Section 4 of P.D. No. 1606, arguing for the former’s primacy as a special law for PNP members.

Maintained that the term “regular courts” includes the Sandiganbayan since it is one of the inferior courts under the judicial department as enumerated in the Administrative Code of 1987.
Emphasized that courts-martial, being part of the executive system, were deliberately divested of jurisdiction over PNP members to preserve the civilian character of the police force.
Reiterated that legislative intent and the harmonization of statutes point to the inclusion of the Sandiganbayan under the ambit of “regular courts.”
Supported the view that even if the offense carries a penalty higher than prision correccional, for the Sandiganbayan to have jurisdiction the information must also allege that the crime was committed in relation to the offender’s office.

The creation of the PNP under R.A. No. 6975 was driven by a constitutional mandate to establish a police force that is national in scope and civilian in character.
During Congressional deliberations, the interchangeable use of the terms “civil courts” and “regular courts” was intended to redirect criminal jurisdiction from military-era courts-martial to courts functioning within the traditional judicial hierarchy, including the Sandiganbayan.
The historical narrative reflects efforts to de-militarize the police force by ensuring that its members are tried in civilian courts, thereby reinforcing the civilian oversight and control.

Whether the term “regular courts” in Section 46 of R.A. No. 6975 includes the Sandiganbayan, given its designation as a special court under constitutional and statutory provisions.
Whether the dismissal of Criminal Case No. Q-91-23224 based solely on the penalty prescribed (reclusion temporal for homicide) and the precedent set in Deloso vs. Domingo was proper.
Whether the information in Criminal Case No. Q-91-23224 sufficiently alleged that the homicide was committed in relation to the respondent’s official duties, which is a necessary requirement to confer exclusive jurisdiction to the Sandiganbayan under Section 4(a)(2) of P.D. No. 1606, as amended.
Whether there exists an irreconcilable conflict between Section 46 of R.A. No. 6975 and Section 4 of P.D. No. 1606, or if the two can be harmonized so that both laws continue to operate effectively.