Title
Geduspan vs. People
Case
G.R. No. 158187
Decision Date
Feb 11, 2005
A Philhealth regional manager challenged Sandiganbayan's jurisdiction over her graft case, arguing her Salary Grade 26 excluded her; the Supreme Court ruled her GOCC managerial position placed her under Sandiganbayan's jurisdiction regardless of salary grade.
jurisdiction
petition
costs

Case Summary (G.R. No. 158187)

Factual Background

The information alleged that on or about November 27, 1999 and for some time thereafter at Bacolod City, petitioner Marilyn C. Geduspan, as Regional Manager/Director of the Philippine Health Insurance Corporation (Philhealth) Region VI, connived with private respondent Dra. Evangelyn Farahmand, Chairman of the Board of Directors of Tiong Bi Medical Center, Tiong Bi, Inc., to willfully release to Tiong Bi Medical Center claims for payments amounting to P91,954.64 that, under a Deed of Conditional Sale executed November 27, 1999, were purportedly collectible by West Negros College, Inc. for accounts accruing prior to January 1, 2000.

Information and Charges

On July 11, 2002 the Office of the Special Prosecutor filed an information docketed as Criminal Case No. 27525 charging Geduspan and Farahmand with violation of Section 3(e) of RA 3019, alleging that the release of the specified insurance claims constituted giving unwarranted benefits in relation to Geduspan’s official functions as a public officer.

Motion to Quash and Proceedings Below

Both accused filed a joint motion to quash dated July 29, 2002, contending that the Sandiganbayan lacked jurisdiction because Geduspan’s position was classified as salary grade 26. The respondent court denied the motion to quash in a resolution dated January 31, 2003 and denied the motion for reconsideration in a resolution dated May 9, 2003. Petitioner Geduspan then filed a petition for certiorari under Rule 65 seeking annulment of those resolutions and prayed for injunctive relief.

Petitioner's Contentions

Geduspan maintained that her appointment paper and notice of salary adjustment established that she was appointed Department Manager A of Philhealth, a position classified under salary grade 26, and therefore outside the Sandiganbayan’s jurisdiction as defined in paragraph (1) and (5), Section 4 of RA 8249, which generally vested the Sandiganbayan with original jurisdiction where one or more accused were officials occupying positions of regional director and higher classified as Grade 27 and higher.

Respondent's Contentions and Lower Court Rulings

The Office of the Special Prosecutor and the Sandiganbayan argued that the pertinent jurisdictional provision of RA 8249 specifically included among officials subject to the Sandiganbayan’s original jurisdiction “presidents, directors or trustees, or managers of government-owned and controlled corporations, state universities or educational institutions or foundations,” thereby bringing managers of government-owned and controlled corporations like Philhealth within the court’s jurisdiction irrespective of salary grade. The respondent court relied on the appointment paper showing Geduspan’s classification as Department Manager A but concluded that it was the position held, not the salary grade, that determined jurisdiction.

Issues Presented

The principal legal question was whether the Sandiganbayan had jurisdiction over a regional director/manager of a government-owned or controlled corporation organized and incorporated under the Corporation Code for purposes of RA 3019, when the position occupied was classified as salary grade 26.

Supreme Court's Analysis and Legal Reasoning

The Court examined the language of Section 4 of RA 8249, noting its two-fold structure: the first part covers officials of the executive branch occupying positions of regional director and higher classified as Grade 27 and higher; the second part expressly includes certain officials whose positions may not be Grade 27 and higher but who are specifically named, among them “presidents, directors or trustees, or managers of government-owned and controlled corporations.” The Court distinguished Ramon Cuyco v. Sandiganbayan, where jurisdiction was denied because the accused was a regional director classified as Director II with salary grade 26 and thus fell outside the Grade 27 threshold. The Court found the instant case materially different because Geduspan held the position of Department Manager A of Philhealth, a manager in a government-owned and controlled corporation, a c

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