Case Summary (G.R. No. L-40106)
Facts of the Case
On October 21, 1980, Mayor Lecaroz was charged with grave coercion for taking control of a gasoline station owned by Pedro Par. The charge alleged that he, leveraging his position, unlawfully managed the station’s operations, including the sale of gasoline, issuing unauthorized invoices, and padlocking the dispensing pump, effectively depriving Par of his lawful business.
Amendments and Motion to Quash
On November 27, 1980, the information against Lecaroz was amended to include his ordering police officers to sell gasoline. Petitioner moved to quash the information, arguing that the Sandiganbayan lacked jurisdiction, and that the case should have been filed in the local courts due to its location in Marinduque. The Sandiganbayan denied his motion, leading to the filing of a petition for certiorari.
Jurisdiction Issues
Petitioner contended that the alleged crime was not related to his responsibilities as mayor and that grave coercion is not established in Section 4(c) of Presidential Decree No. 1486 as a crime subject to Sandiganbayan jurisdiction. However, Section 5, Article XIII of the 1987 Constitution clearly states that the Sandiganbayan has jurisdiction over offenses committed by public officers in relation to their office.
Interpretation of Jurisdictional Provisions
The framers of the New Constitution intended for the Sandiganbayan to address not only graft and corrupt practices but also other crimes related to public office. The lawmaking body is bestowed with the authority to define these "other offenses," which ensures that the Sandiganbayan retains jurisdiction over the grave coercion charge against Lecaroz. This charge, stemming from the alleged abuse of power as a public officer, is thus within the respondent court's jurisdiction.
Nature of the Offense
The facts indicate that Lecaroz took advantage of his position as mayor to coerce the gasoline station’s owner. The act of directing police to enforce his orders and unlawfully conducting business operations reflects an abuse of authority. It is noted that if Lecaroz were not the mayor, he would likely not have directed such actions, thus linking the offense to his public office.
Concurrent Jurisdiction and Legal Precedent
According to Section 4 of Presidential Decree No. 1606, the Sandiganbayan has concurrent jurisdiction with ordinary courts for crimes committed by public officers. The principle established in Laquian vs. Baltazar affirms that once a court has jurisdiction over a case, it retains that jurisdiction to the exclusion of other courts. Therefore, the Sandiganbayan’s denial to transfer the case to the local courts was justified and not a display of grave abuse of discretion.
Legislative Changes and Applicability
Presidential Decree No. 1861 later outlined changes regarding the jurisdictional scope of the Sandiganbayan for offenses with penalties not exceeding certain thresholds. However, the applicability of this decree does not impact the case against Lecaroz
...continue readingCase Syllabus (G.R. No. L-40106)
Case Overview
- The case involves Mayor Francisco Lecaroz, who was charged with grave coercion in relation to his position as a public officer.
- The incident took place on July 2, 1979, in Sta. Cruz, Marinduque, where Lecaroz allegedly took control of a gasoline station owned by Pedro Par.
- The information filed against him detailed how he used his position to intimidate Par and unlawfully control the operations of the gasoline station.
Charges and Allegations
- The original information filed on October 21, 1980, accused Lecaroz of grave coercion, highlighting that he:
- Took control of Pedro Par's gasoline station.
- Sold gasoline without legal authority.
- Issued invoices on yellow pad paper.
- Used threats and violence to deprive Par of his lawful trade.
- An amendment to the information on November 27, 1980, added that Lecaroz ordered his policemen companions to assist in selling the gasoline.
Motion to Quash
- Lecaroz filed a motion to quash the information, arguing:
- The Sandiganbayan lacked jurisdiction, asserting the case should be heard by ordinary courts in Marinduque.
- The offense was not related to his office as mayor.
- Grave abuse of discretion in denying the transfer of the case given the location of witnesses.
Jurisdictional Issues
- The Sandiganbayan's jurisdiction is defined in Section 5, Article XIII of the Constitution, which grants it authority over cases involving public officers related to their office.
- The court's jurisdiction extends beyond graft and cor