Case Summary (G.R. No. 28702)
Applicable Law
The central legislative provision under scrutiny is Section 46 of Republic Act No. 6975, which specifies that "criminal cases involving PNP members shall be within the exclusive jurisdiction of the regular courts." The interpretation of "regular courts" is pivotal as it determines whether the Sandiganbayan—the anti-graft court—falls within or outside this jurisdiction. The case is analyzed under the 1987 Constitution of the Philippines.
Factual Background
On July 31, 1991, Alexander Dionisio, while on duty as a member of the PNP, shot T/Sgt. Romeo Sadang. The Office of the City Prosecutor filed homicide charges against Dionisio in the RTC of Quezon City, where the case was assigned as Criminal Case No. Q-91-23224. The trial began, but on September 4, 1992, the respondent judge raised jurisdictional concerns, citing a precedent (Deloso vs. Domingo) that jurisdiction over offenses committed by public officials was with the Sandiganbayan if the penalty exceeds prision correccional.
Judicial Actions and Rulings
On September 24, 1992, the RTC judge dismissed the case for re-filing with the Sandiganbayan, asserting that the nature of the charge warranted jurisdiction by the Sandiganbayan. A subsequent motion for reconsideration by the private prosecutor was denied. The judge reiterated that the term "regular courts" included the Sandiganbayan, aligning with precedents that emphasized jurisdiction over public officers, regardless of the alleged connection to their official duties.
Petitioner’s Argument
The petitioner contended that the RTC should retain jurisdiction over the case, arguing that the Sandiganbayan is a special court and, thus, does not fit the designation of "regular courts" in Section 46 of R.A. No. 6975. The petition placed significant emphasis on the definitions laid out in the 1973 Constitution and the 1987 Constitution, arguing against the inclusion of the Sandiganbayan within the directive of the law governing PNP member prosecutions.
Ombudsman’s Position
The Ombudsman, in support of the RTC's dismissal, contended that "regular courts" does include the Sandiganbayan. They posited that the pivotal concern was the character and jurisdiction of the courts, asserting that the regular courts are meant to encompass those courts that function within the judicial department, including the Sandiganbayan as per its creation under established law.
Interpretation of Jurisdiction
The crux of the dispute centered around the interpretation of "regular courts." The analysis determined that the legislative intention behind R.A. No. 6975 sought to establish a clear distinction between military and civilian jurisdictions for PNP members. Thus, the provision aimed to dives
...continue readingCase Syllabus (G.R. No. 28702)
Background of the Case
- The case involves the Republic of the Philippines as the petitioner against Hon. Maximiano C. Asuncion, presiding judge of the Regional Trial Court (RTC), Quezon City, and Alexander Dionisio y Manio, the private respondent.
- The main legal question pertains to Section 46 of Republic Act No. 6975, which addresses the jurisdiction over criminal cases involving Philippine National Police (PNP) members.
- The petitioner argues that the term "regular courts" does not include the Sandiganbayan, while the respondents argue that it does.
Relevant Statutory Provisions
- Section 46 of Republic Act No. 6975: States that criminal cases involving PNP members shall be under the exclusive jurisdiction of regular courts.
- The section specifies that courts-martial will continue to try certain cases involving PNP members who have already been arraigned.
Factual Antecedents
- On July 31, 1991, Alexander Dionisio, a PNP member, shot and killed T/Sgt. Romeo Sadang while responding to a complaint in Novaliches, Quezon City.
- The Office of the City Prosecutor charged Dionisio with homicide on August 7, 1991, leading to the docketing of Criminal Case No. Q-91-23224 in RTC Branch 104.
Procedural History
- After trial commenced, the respondent Judge raised the issue of jurisdiction based on a previous Supreme Court ruling in Deloso vs. Domingo, asserting that the Sandiganbayan had jurisdiction over offenses committed by public officials if the penalty was higher than prision correctional.
- On September 24, 1992, the Judge dismissed the case for re-filing