Case Summary (G.R. No. 134102)
Jurisdictional Issue
This case involves the determination of jurisdiction over a Petition for Certiorari with Prohibition filed by Teodoto B. Abbot. The core dispute is whether such jurisdiction lies with the Court of Appeals or the Sandiganbayan. Abbot contends that the Court of Appeals is the appropriate tribunal, whereas both the Court of Appeals and the Office of the Solicitor General assert that jurisdiction rests with the Sandiganbayan.
Factual Background
Abbot was charged with Malversation Thru Falsification of Public Document for allegedly falsifying payroll records that resulted in personal gain of PHP 19,500. The initial Information was filed in the Sandiganbayan but was later transferred to the Regional Trial Court (RTC) due to the enactment of Republic Act No. 7975. Abbot pleaded not guilty and subsequently filed an Omnibus Motion for dismissal, arguing that the funds ceased to be public money once they were indorsed to him.
Regional Trial Court Proceedings
On October 29, 1996, the RTC denied Abbot’s Omnibus Motion, and his subsequent Motion for Reconsideration filed on February 12, 1997, was also denied. Abbot appealed these orders to the Court of Appeals through a Petition for Certiorari with Prohibition, claiming grave abuse of discretion and asserting that the Information was quashable because it did not constitute an offense.
Court of Appeals Findings
Upon review, the Court of Appeals, agreeing with the Solicitor General's position, dismissed the Petition for lack of jurisdiction, reinforcing the idea that jurisdiction belonged to the Sandiganbayan. The Court of Appeals later denied Abbot's Motion for Reconsideration.
Legislative Background on Jurisdiction
The Sandiganbayan was established under Presidential Decree No. 1606, which delineates its exclusive original jurisdiction over specific offenses related to public officials. Following the decision in Garcia, Jr. v. Sandiganbayan, Congress enacted Republic Act No. 7975, which expanded the Sandiganbayan's jurisdiction to include petitions for extraordinary writs such as certiorari, mandamus, and prohibition.
Conclusion on Jurisdiction
The enactment of RA 7975 effectively supplanted the ruling in Garcia, Jr. v. Sandiganbayan, thereby providing the Sandiganbayan the authority to hear petitions for writs of
...continue readingCase Syllabus (G.R. No. 134102)
Case Background
- The case revolves around the jurisdictional conflict regarding a Petition for Certiorari with Prohibition filed by petitioner Teodoto B. Abbot.
- Petitioner claims that the Court of Appeals has the jurisdiction to hear his Petition, while the Court of Appeals, along with the Office of the Solicitor General, contends that the case falls under the jurisdiction of the Sandiganbayan.
Parties Involved
- Petitioner: Teodoto B. Abbot, Chief of the Irrigation System, Mal-River Project, National Irrigation Administration, located in Manga, Matanao, Davao del Sur.
- Respondents: Hon. Judge Hilario I. Mapayo, Presiding Judge of RTC-Br. 19, Digos, Davao del Sur, and the People of the Philippines.
Charges and Allegations
- Petitioner was charged with "Malversation Thru Falsification of Public Document."
- The accusation stated that Abbot falsified the Viability Incentive Grant payroll, claiming that seven complaining witnesses received higher amounts than they actually did, allowing him to misappropriate a total of P19,500.00.
Procedural History
- The case was initially lodged before the Sandiganbayan but was later transferred to the Regional Trial Court (RTC) due to RA 7975.
- Abbot pleaded not guilty during his arraignment and subsequently filed an Omnibus Motion seeking dismissal of the case, arguing that the funds in question were no longer public funds once they were encashed.
RTC Decisions
- The RTC denied Abbot's Omnibus Motion on October 29, 1996, stati