G.R. No. 174536 - Ponciano, Jr. vs. Laguna Lake Development Authority

Petitioners: Conrado B. Rodrigo, Jr., Alejandro A. Facundo, and Reynaldo G. Mejica.
Respondents: The Honorable Sandiganbayan (First Division), Ombudsman, and People of the Philippines.

The petitioner Mayor’s position was classified under Salary Grade 27 pursuant to Republic Act (R.A.) No. 6758.
The case involves a charge under Section 3(e) of R.A. No. 3019, relating to acts of graft and corruption.
The jurisdiction of the Sandiganbayan over the petitioners was upheld in a prior decision dated 18 February 1999, based on petitioners’ qualification within the jurisdictional ambit defined by Section 4(a) of Presidential Decree (P.D.) No. 1606, as amended by R.A. No. 7975.

The Compensation and Position Classification Act of 1989 and its Index of Occupational Services, Position Titles and Salary Grades detail the method for determining the appropriate salary grade for government positions.
For positions not specifically listed, such as that of Municipal Mayor, the Index is prepared by the Department of Budget and Management (DBM) pursuant to guidelines set forth in Section 9 of the said Act.
The DBM’s Index ultimately assigned the Municipal Mayor a Salary Grade of 27.

Petitioners argued that the DBM was merely tasked with “preparing” the Index; hence, a separate law was necessary to adopt the Index with full force and effect.
It was contended that by delegating this function to the DBM, the executive branch effectively determined, in part, the jurisdiction of the Sandiganbayan, which amounted to an undue delegation of legislative power.
Petitioners questioned whether the authority given to the DBM extended to making consequential changes in judicial jurisdiction.

Section 444(d) of the Local Government Code was cited, which explicitly confirms that the Municipal Mayor is entitled to a minimum monthly compensation corresponding to Salary Grade 27.
Relevant provisions in R.A. No. 6758 and P.D. No. 1606, as amended by R.A. No. 7975, were examined to determine the scope of DBM’s authority and the resultant jurisdiction of the Sandiganbayan.

The case also explored the principle of delegation of legislative power, emphasizing that Congress may delegate certain administrative functions to specialized agencies.
The rationale provided underscored that such delegation enables efficient administration and allows Congress to focus on broader policy issues.
Petitioners further raised practical concerns regarding the inconvenience of assembling witnesses from distant locations (Baguio City and San Nicolas, Pangasinan), though this argument was ultimately secondary to the legal question of jurisdiction.

Whether the assignment of Salary Grade 27 to the Municipal Mayor, as determined by the DBM, renders the petitioner and his co-accused subject to the exclusive and original jurisdiction of the Sandiganbayan.

Whether the DBM's role in preparing the Index of Occupational Services, Position Titles and Salary Grades is sufficient, without additional legislative enactment, to confer legal effect and establish judicial jurisdiction.

Whether the delegation of the authority to assign salary grades (thus determining jurisdiction for anti-graft purposes) to the DBM constitutes an undue delegation of legislative powers.

Whether the delegation in question, and the subsequent application of jurisdiction by the Sandiganbayan, improperly encroaches upon the separation of powers, thereby upsetting the balance between the legislative and executive functions.