G.R. No. 111616 - Natividad vs. Felix

Case Summary (G.R. No. 111616)

Applicable Law

The case revolves around the interpretation of Section 15 of Republic Act No. 6770 (The Ombudsman Act of 1989) and its relation to the jurisdiction of the Sandiganbayan, as guided by the 1987 Philippine Constitution.

Factual Background

The factual background indicates that a preliminary investigation into the death of Severino Aquino was initiated by the Tarlac Provincial Prosecutor following a complaint filed by Aquino's wife. This led to the issuance of a subpoena requiring the petitioner to submit a counter-affidavit. During this ongoing process, additional criminal complaints were filed against the petitioner, resulting in the issuance of arrest warrants at various points in time. A sequence of court orders and motions resulted, including a motion for the case to be remanded for further investigation, which ultimately led to the trial court recalling the initial warrant of arrest.

Judicial Authority and Preliminary Investigation

The primary legal question is the authority of the provincial prosecutor to conduct a preliminary investigation into alleged criminal conduct by a public official. The petitioner challenged the jurisdiction of the provincial prosecutor based on interpretations of the law, asserting that the Ombudsman holds primary jurisdiction over cases cognizable by the Sandiganbayan.

Interpretation of the Ombudsman Act

The petitioner referenced Section 15(1) of the Ombudsman Act, which grants the Ombudsman the power to investigate actions taken by public officials and contended that this encompassed any alleged wrongdoing by public officials, regardless of their ties to their official duties. The case law cited included Deloso v. Domingo, which provided substantial support for the petitioner’s arguments concerning the jurisdictional scope of the Ombudsman.

Historical Jurisdictional Framework

The Court examined the historical context of the jurisdiction of the Sandiganbayan, tracing relevant presidential decrees which establish the parameters of jurisdiction for public officials’ offenses. The current legislation asserts that for an offense committed by public officers to fall under the Sandiganbayan's jurisdiction, it must relate to the public officer's official duties and carry a sufficient penalty.

Application to the Present Case

Applying the pertinent laws to the facts of this case, the Court found that while the murder charge against the petitioner met the penalty threshold for Sandiganbayan jurisdiction, the requirement that the offense must be committed "in relation to" the officer's duties was not satisfied. The nature of the offense, alleged murder, was found not to be an act performed in the scope of the mayor's official powers.

Concurrent Jurisdiction of Investigative Agencies

Despite the primary jurisdiction of the Ombudsman, the Court clarified that it does not imply an exclusive authority, as it merely indicates a concurrent jurisdiction with other investigative agenci