Title
Serana vs. Sandiganbayan
Case
G.R. No. 162059
Decision Date
Jan 22, 2008
A student regent, appointed by the president, faced estafa charges for misusing funds allocated for a university project, ruled as a public officer under Sandiganbayan jurisdiction.

Case Digest (G.R. No. 119064)
Expanded Legal Reasoning Model

Facts:

  • Antecedents
    • Petitioner Hannah Eunice D. Serana, a University of the Philippines scholar, served as Student Regent from January 1 to December 31, 2000 by appointment of President Joseph Estrada.
    • On September 4, 2000, petitioner and her relatives incorporated the Office of the Student Regent Foundation, Inc. (OSRFI) to undertake projects including the renovation of Vinzons Hall Annex, UP Diliman.
    • President Estrada released Fifteen Million Pesos (₱15,000,000.00) to OSRFI as financial assistance for the renovation, which never occurred.
  • Complaint and Indictment
    • Successor student regent and student leaders filed a complaint for malversation with the Office of the Ombudsman.
    • On July 3, 2003, the Ombudsman found probable cause and indicted petitioner and her brother under Article 315(2)(a) of the Revised Penal Code for estafa, docketed as Sandiganbayan Criminal Case No. 27819.
    • The Information alleges that petitioner, using her position, defrauded the government by falsely representing the renovation project to President Estrada, procuring a ₱15 million check, which her brother encashed for personal use.
  • Motion to Quash and Sandiganbayan Resolutions
    • Petitioner moved to quash, arguing the Sandiganbayan lacks jurisdiction over estafa (Title X, RPC) and that she was not a public officer nor acted in relation to her office; claimed funds came personally from Estrada.
    • The Sandiganbayan, Fifth Division, denied the motion (November 14, 2003) and the motion for reconsideration (February 4, 2004), holding jurisdiction under Section 4(A)(1)(g) and 4(b) of P.D. 1606 (as amended by R.A. 8249) and that source of funds is a trial defense.

Issues:

  • Whether the Sandiganbayan has jurisdiction over the crime of estafa committed by petitioner.
  • Whether Hannah Eunice D. Serana, as UP Student Regent, qualifies as a public officer under P.D. 1606, as amended.
  • Whether the offense was committed in relation to petitioner’s official functions.
  • Whether the ₱15 million allegedly came from the government coffers or private funds of President Estrada.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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