Case Summary (G.R. No. L-51739)
Charges and Information
The information alleged that between March 2 to March 15, 1974, in Surigao City, Manuel, while serving as a Mining Engineer with the Bureau of Mines, prepared and caused the preparation of false official documents—specifically, an Itinerary of Travel and a Daily Time Record. The documents falsely stated that Manuel was engaged in fieldwork on several dates when, in reality, he was neither in the field nor present in his office. The fraudulent actions enabled him to claim and misappropriate a total amount of ₱344.67, which he wrongfully withdrew for his personal use, thereby defrauding the government.
Procedural History
Upon the filing of the information on January 19, 1979, an arrest order was issued, but Manuel posted bail for his provisional liberty immediately thereafter. Despite numerous attempts at arraignment, he was never formally arraigned. On February 21, 1979, Manuel’s counsel filed a motion seeking to quash the information or, in the alternative, to transfer the case to the Sandiganbayan, asserting that the jurisdiction lies with that court due to the nature of the charges. This motion was subsequently denied by the lower court on August 7, 1979.
Legal Framework and Jurisdictional Arguments
Manuel argued that the jurisdiction over his case should rest with the Sandiganbayan based on Section 4 of Presidential Decree No. 1606, which grants exclusive jurisdiction to the Sandiganbayan for offenses committed by public officers when penalties surpass prision correccional. He contended that the falsification charge under Article 171 of the Revised Penal Code is punishable by prision mayor, thus establishing the Sandiganbayan's exclusive jurisdiction over the case.
In contrast, the respondents argued that the estafa committed by Manuel involved a low amount of ₱344.67, thereby attracting penalties under Article 315 of the Revised Penal Code, which falls within the minimum period of prision correccional. They maintained that since the Court of First Instance of Surigao del Sur was the first to acquire jurisdiction, the case should remain with that court.
Court's Analysis and Conclusion
The court ultimately sided with Manuel, asserting that the charges constituted a complex crime. It reasoned that in c
...continue readingCase Syllabus (G.R. No. L-51739)
Case Overview
- The case involves Florentino T. Manuel, the petitioner, who was charged with estafa through falsification of public documents.
- The information was filed on January 19, 1979, in the Court of First Instance of Surigao del Sur, assigned Criminal Case No. 850.
- The charge stemmed from allegations that Manuel prepared false travel itineraries and daily time records while employed as a Mining Engineer with the Bureau of Mines in Surigao City.
Charges and Allegations
- The information states that from March 2 to 15, 1974, Manuel willfully falsified documents indicating he was on fieldwork.
- Specific dates were highlighted where he purportedly claimed to be in various locations (Placer, Dinagat, and Nonoc Island) while he was neither on fieldwork nor present in the office.
- As a result of these falsifications, he prepared a general voucher to collect per diem and daily allowances amounting to P344.67, thus defrauding the Government of the Philippines.
Legal Proceedings
- Following the filing of the information, an arrest order was issued, but Manuel was able to post bail for provisio