Title
Lacson vs. Executive Secretary
Case
G.R. No. 128096
Decision Date
Jan 20, 1999
Petitioners challenged the constitutionality of R.A. No. 8249 which altered Sandiganbayan's jurisdiction in pending murder cases, arguing it violated their due process rights. Court upheld the law, finding no ex post facto application.

Case Summary (G.R. No. 128096)

Key Dates

  • May 18, 1995: Incident and killings
  • Nov. 2, 1995: Original murder informations filed before the Sandiganbayan under R.A. 7975
  • Mar. 1, 1996: Amended informations recharacterizing Lacson and others as accessories
  • May 9, 1996: Sandiganbayan Second Division orders transfer of cases to the Quezon City Regional Trial Court (RTC) for lack of jurisdiction under R.A. 7975
  • Feb. 25, 1997: Effectivity of R.A. 8249, which expands Sandiganbayan jurisdiction (Section 4) and applies retroactively to pending cases (Section 7)
  • Jan. 20, 1999: Supreme Court decision

Applicable Law

  • 1987 Constitution (due process, equal protection, separation of powers)
  • Presidential Decree No. 1606 (original Sandiganbayan creation)
  • Republic Act No. 7975 (1995 amendments defining Sandiganbayan jurisdiction, requiring a “principal accused” of Grade 27 or PNP Chief Superintendent or higher)
  • Republic Act No. 8249 (1997 amendments deleting “principal” requirement and applying jurisdictional changes to all pending cases where trial has not begun)

Procedural History

  1. Murder charges under R.A. 7975 filed against Lacson (as principal) and Acop/Zubia (as accessories).
  2. Upon amendment, all accused downgraded to accessories, prompting a jurisdictional motion: with no principal of requisite grade or rank, the RTC must take cognizance.
  3. Sandiganbayan (2nd Division) grants transfer to RTC on May 9, 1996.
  4. Congress enacts R.A. 8249, expanding Sandiganbayan jurisdiction by removing the “principal” requirement (Section 4) and making the law applicable to all pending cases not yet tried (Section 7).
  5. Sandiganbayan reverses itself by addendum on Mar. 5, 1997, retains jurisdiction.
  6. Petition for prohibition and mandamus challenges constitutionality of Sections 4 and 7, and asserts lack of Sandiganbayan jurisdiction.

Issues Presented

  1. Whether Sections 4 and 7 of R.A. 8249 violate due process, equal protection, one-title-one-subject, or constitute ex post facto or class legislation.
  2. Whether, under R.A. 8249 and the allegations in the amended informations, the Sandiganbayan has jurisdiction over the multiple murder charges.

Petitioners’ and Intervenors’ Contentions

  • Sections 4 and 7 enacted in bad faith to secure Sandiganbayan jurisdiction over the Kuratong Baleleng cases, depriving petitioners of vested procedural rights under R.A. 7975.
  • Retroactive application is ex post facto and violates procedural due process.
  • The title of R.A. 8249 is misleading, breaching Article VI, Section 26(1) (one subject per bill).
  • Removal of “principal” classification targeted only these cases, amounting to class legislation and unequal protection.

Respondents’ Position

  • R.A. 8249 validly exercises Congress’s power to define court jurisdiction; the transitory provision is necessary when jurisdiction changes.
  • The statute is procedural, not penal, and its retroactivity does not offend the ex post facto prohibition.
  • Classification is reasonable; the title sufficiently indicates the law’s general purpose.
  • Under Section 4 as amended, the Sandiganbayan acquires exclusive original jurisdiction over all offenses by enumerated public officers (regardless of status as principal, accomplice, or accessory) when committed in relation to office.

Supreme Court’s Analysis

  1. Presumption of Constitutionality: Challengers bear burden to prove clear constitutional breach.
  2. Legislative Power over Jurisdiction: Under Article XI, Section 4 (1987 Constitution) and Article XIII, Section 5 (1973 Constitution), Congress defines Sandiganbayan jurisdiction.
  3. Reasonable Classification and Equal Protection: Deletion of “principal” requirement and retroactive application via Section 7 are supported by substantial distinctions (cases with pending trials vs. those where trial commenced). Transitory provisions are standard when altering court jurisdiction.
  4. Ex Post Facto and Due Process: R.A. 8249 is procedural, not penal; it neither creates new crimes nor increases penalties. Retroactive application to pending cases does not violate ex post facto ban or procedural due process rights, and the statutory right of appeal may be regulated.
  5. One-Title-One-Subject: The title of R.A. 8249 adequately expresses its general purpose to define Sandiganbayan jurisdiction and amend P.D. 1606; all provisions are germane.

Jurisdictional Requirement and Factual Allegations

  • Under Section 4(b) of R.A. 8249, the Sandiganbayan’s original jurisdiction extends to “other offenses or felonies” by enumerated public officers “in relation to their office.”
  • Jurisdiction depends on factual allegations in the information demonstrating that the crime was committed while performing official functions
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