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)

Material Facts

On May 18, 1995, 11 persons alleged members of the Kuratong Baleleng were killed by elements of an anti-crime PNP task group. Initial Ombudsman investigation (Blancaflor panel) cleared the officers; a review board later recommended multiple murder indictments against 26 respondents. On November 2, 1995 Lacson and others were charged before the Sandiganbayan. After a reinvestigation, the Ombudsman filed amended informations on March 1, 1996 that reduced some parties and recast charges; under the amended informations Lacson and intervenors were charged as accessories after-the-fact. On May 8, 1996 the Sandiganbayan Second Division ordered transfer of the amended informations to the Quezon City Regional Trial Court (RTC) under RA 7975. While motions for reconsideration were pending, Congress enacted RA 8249 (approved February 5, 1997; effective February 25, 1997), deleting the word “principal” from the operative jurisdictional text and containing a transitory provision applying the act to “all cases pending in any court over which trial has not begun.” On March 5, 1997 the Sandiganbayan reversed course in light of RA 8249 and retained jurisdiction; the petition followed.

Procedural Posture and Relief Sought

Petitioners sought prohibition and mandamus to enjoin the Sandiganbayan from proceeding and to require transfer of Criminal Cases Nos. 23047–23057 (multiple murder) to the RTC. They challenged the constitutionality of Sections 4 and 7 of RA 8249, alleging bad faith/class legislation, retroactivity/ex post facto effect, denial of procedural due process and equal protection, and violation of the one-subject-in-title rule. Intervenors made similar contentions and additionally argued that the removal of the intermediate appellate review impaired their rights.

Text and Effect of RA 8249 (Sections 4 and 7)

Section 4 of RA 8249 amended PD 1606’s jurisdictional provision so that the Sandiganbayan “shall exercise exclusive original jurisdiction in all cases involving” enumerated graft- and related-offenses as well as “other offenses or felonies whether simple or complexed with other crimes” committed by listed public officials “in relation to their office.” The amendment removed the word “principal” that previously qualified “accused” in RA 7975. Section 7 is a transitory provision stating the act “shall apply to all cases pending in any court over which trial has not begun as of the approval hereof.”

Legal Issue Presented

(1) Whether Sections 4 and 7 of RA 8249 are constitutional under the 1987 Constitution (due process, equal protection, ex post facto prohibition, and one-subject-in-title rule). (2) Whether, on the face of the amended informations, the Sandiganbayan has exclusive original jurisdiction over the murder charges or whether jurisdiction lies with the RTC because the information fails to allege that the offenses were committed “in relation to” the accused’s official functions.

Presumption of Constitutionality and Burden of Proof

The Court reiterates the presumption that every law is constitutional and that challengers bear the burden of proving a clear constitutional violation. The petitioners and intervenors did not meet that burden; their evidence and arguments were insufficient to demonstrate that RA 8249 was enacted in bad faith, or that the statute is arbitrary class legislation.

Equal Protection and Class Legislation Claim

The Court applied the standard for reasonable classification (four elements: substantial distinction, germane to the law’s purpose, not limited to existing conditions only, and uniform application to the class). It found that the classification between pending cases where trial had not begun and cases where trial had already commenced rests on substantial and relevant distinctions (e.g., absence of presented evidence in the former). RA 8249’s transitory provision covered all pending cases in any court and was not limited to the Kuratong Baleleng cases; the petitioners failed to rebut the presumption of reasonableness.

Ex Post Facto, Procedural Due Process and Right of Appeal

The Court held RA 8249 is not an ex post facto or penal law because it defines jurisdiction (a substantive jurisdictional/adjectival provision), does not create or increase criminal liability, does not change punishment, nor alters rules of evidence to the accused’s disadvantage. Procedural rights such as statutory modes of appeal are not natural rights and may be altered by statute; the elimination of an intermediate appellate review did not violate the ex post facto clause or deny procedural due process because the accused retained the right to appeal to the Supreme Court on questions of law and the statute did not impair substantive protections.

One-Subject-in-Title Challenge

The Court rejected the contention that RA 8249’s title was misleading. The Constitution requires that a bill embrace one subject expressed in its title; the title here—stating it further defines the jurisdiction of the Sandiganbayan and amends PD 1606—was sufficiently comprehensive. The provisions are germane to the general subject and the title need not recite every consequence of the amendments.

Governing Rule on Jurisdictional Allegations

Jurisdiction of a court is determined by the allegations in the complaint or information, not by evidence at trial. Under RA 8249 Section 4(b), the Sandiganbayan has jurisdiction over “other offenses or felonies ... committed by the public officials and employees mentioned in subsection a ... in relation to their office.” The “in relation to” requirement means the offense must be “intimately connected” with the office and committed in the performance of official functions. Such intimate relation must be pleaded with factual particularity in the information; mere conclusions of law are insufficient.

Application to the Amended Informations — Sufficiency of Allegations

The Court examined an exemplar amended information. Although it baldly alleged that the principal accused “took advantage of their public and official positions” and committed the shootings

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