Case Summary (G.R. No. 143264)
Jurisdictional Issue
The case primarily revolves around whether the Sandiganbayan has jurisdiction over criminal cases involving mayors of fifth-class municipalities, specifically in relation to Mayor Layus's classification under the Compensation and Position Classification Act of 1989. Mayor Layus contends that her monthly salary of P11,441 places her under Salary Grade (SG) 25, which is below the SG 27 threshold necessary for the Sandiganbayan’s jurisdiction.
Procedural Background
The Ombudsman recommended filing an information for estafa through falsification of public documents, against Mayor Layus, following a preliminary investigation. Layus contended that she was unaware of the filing of the information and thus filed a motion for reconsideration, which was denied.
Sandiganbayan Proceedings
Throughout the proceedings, Layus filed several motions, including to quash the information and for reinvestigation, which the Sandiganbayan consistently denied. The primary argument against jurisdiction was based on her salary classification, which she argued should exempt her from being tried in the Sandiganbayan.
Pre-Suspension Hearing and Mandatory Suspension
The Sandiganbayan held that the information filed against Layus was valid and opined that under Section 13 of RA 3019, a mandatory preventive suspension was warranted for any public officer facing criminal prosecution, which was further upheld despite her arguments against the constitutionality and rationality of the 90-day suspension period.
Legal Standards and Rulings
The Court cited precedents and legislative provisions, establishing that jurisdiction is determined not solely by salary but by statutory classification of public officials. It was reinforced that the existence of
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Case Overview
- This case is a special civil action for certiorari and prohibition, filed under Rule 65 of the Rules of Court.
- Petitioner Celia T. Layus, M.D. (LAYUS), the elected Mayor of Claveria, Cagayan, contests the jurisdiction of the Sandiganbayan in criminal cases involving mayors of fifth-class municipalities.
- The case centers around Criminal Case No. 23583, wherein LAYUS was charged with estafa through falsification of public documents.
Background of the Case
- The Information against LAYUS was filed on 19 February 1997, stemming from a complaint that included allegations of estafa through falsification of public documents, and violations of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019).
- A Joint Resolution dated 21 November 1996 recommended filing charges against LAYUS, while dismissing others involved.
- LAYUS claims she received the Joint Resolution on 21 February 1997 and subsequently filed a motion for reconsideration on 7 March 1997, unaware that the Information had already been filed.
Procedural History
- LAYUS was arrested on 8 April 1997 and posted bail for her temporary liberty.
- She sought to lift a travel ban imposed by the Sandiganbayan, which coincided with her planned trip abroad.
- On 18 April 1997, she entered a plea of not guilty under the condition that it would not waive her rights to file for reinvestigation and to quash the Information.