Case Summary (G.R. No. 136916)
Relevant Facts
On August 15, 1997, the Sandiganbayan received an Information accusing multiple individuals, including Lilia B. Organo, of committing plunder by unlawfully acquiring public funds through unauthorized means. These acts involved significant amounts of money misappropriated from the National Government via an unauthorized bank account. Subsequently, a warrant of arrest was issued against Organo on September 29, 1997, after she filed a motion to quash the information, which was later denied by the Sandiganbayan. Organo remained under detention after filing a petition for certiorari and prohibition with the Supreme Court, challenging the legality of the warrant and the jurisdiction of the Sandiganbayan.
Jurisdictional Issue
The primary legal question presented is whether the Sandiganbayan has jurisdiction to hear cases of plunder when none of the accused individuals occupy positions corresponding to Salary Grade 27 or higher. The petitioner argues that jurisdiction is lacking based on sections of Republic Acts Nos. 6758, 7080, and 8249, which delineate jurisdictional boundaries.
Court's Ruling on Jurisdiction
The Supreme Court found in favor of the petitioner, declaring that the Sandiganbayan's jurisdiction is confined to cases where the accused public officials are of Salary Grade 27 or higher. While Republic Act No. 7080 initially placed plunder under the jurisdiction of the Sandiganbayan, subsequent legislation—namely Republic Act No. 8249—impliedly repealed its scope by establishing specific criteria based on salary grade. The Court referenced prior rulings that reinforced this understanding, categorically stating that the jurisdiction of the Sandiganbayan over plunder cases is contingent upon the salary grade of the accused.
Legislative Intent and Implications
The Court emphasized that the intention behind enacting Republic Act No. 8249 was to relieve the Sandiganbayan of low-ranking cases and enable it to focus on high-ranking officials, therefore providing clarity on the jurisdictional limits based on Salary Grade. The explanation provided in the legislative notes identified Salary Grade 27 a
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Case Overview
- The case arises from a Petition for Habeas Corpus filed by Fleurdeliz B. Organo, seeking the release of her mother, Lilia B. Organo, from detention.
- The detention was based on a Warrant of Arrest issued by the Sandiganbayan in connection with an Information for plunder.
- The crux of the petition is the alleged lack of jurisdiction of the Sandiganbayan over the case against Lilia B. Organo, as she does not occupy a position corresponding to Salary Grade 27 or higher.
Background Facts
- On August 15, 1997, several accused, including Lilia B. Organo, were charged with plunder under Republic Act No. 7080.
- The allegations against them include opening an unauthorized bank account and misappropriating funds belonging to the National Government.
- The Sandiganbayan was initially assigned to the case, but jurisdiction was questioned by Lilia B. Organo through a Motion to Quash.
- The case was reassigned to the 4th Division of the Sandiganbayan, which subsequently issued a Warrant of Arrest against the accused.
Legal Arguments
- Lilia B. Organo argues that the Sandiganbayan lacks jurisdiction since she does not occupy a position with Salary Grade 27 or higher.
- The prosecution contends that the Sandiganbayan retains jurisdiction over pl