Case Summary (G.R. No. 105965-70)
Legal Background and Events Leading to the Case
On July 2, 1991, six informations for estafa through falsification of official documents and one information for violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) were filed against Uy and nineteen co-accused. The proceedings were initiated by Captain Luisito F. Fernandez, who authorized Uy to act on his behalf. An order for a comprehensive re-investigation was issued by the Sandiganbayan on September 20, 1991. Following the investigation, the Special Prosecutor recommended a reduction in the number of charges and filed six amended informations against Uy and other officials.
Petitioner’s Motion to Quash
On April 21, 1992, the petitioner filed a motion to quash the informations, asserting several grounds: lack of jurisdiction by the Sandiganbayan, lack of authority of the filing officer, failure of the facts to constitute an offense, and improper multiple charges for what should be a single offense. The Sandiganbayan denied this motion on June 10, 1992, stating it had jurisdiction over military officers in related to their roles and confirmed that the allegations constituted sufficient grounds for the charges.
Issues Raised in the Petition
The petitioner raised three main issues for consideration: (1) Jurisdiction of the Sandiganbayan over the cases; (2) The authority of the Ombudsman and Special Prosecutor to file the amended information; and (3) Whether the acts charged against him constituted an offense.
Jurisdiction of the Sandiganbayan
Petitioner claimed that as a member of the Armed Forces, he should be tried by a court-martial under P.D. 1850, which had been amended by Republic Act No. 7055. It was contended that all crimes committed by military personnel should be under court-martial jurisdiction unless specified otherwise. The petitioner argued that the charges against him were also "service-connected" under Section 1 of R.A. No. 7055.
Applicable Law and Jurisdictional Analysis
However, the Sandiganbayan's jurisdiction, as outlined under Republic Act No. 8249, which amended the Sandiganbayan Law, specifies that exclusive jurisdiction exists over government officials holding certain ranks, particularly those at or above the rank of captain. Since Uy is classified as a lieutenant commander, which does not meet the threshold rank stipulated, the proper venue for jurisdiction shifted to the regional trial courts. Thus, the Sandiganbayan lacked jurisdiction over the case involving Uy at the time of the informations' filings.
Conclusion on Jurisdiction and Prosecution
The ruling determined that Uy's case belonged to the jur
...continue readingCase Syllabus (G.R. No. 105965-70)
Case Overview
- The case involves a petition for certiorari and prohibition filed by George Uy, seeking to annul the resolution of the Sandiganbayan that denied his motion to quash six informations for violation of Section 3(e), R.A. No. 3019, as amended.
- The petitioner was previously the Deputy Comptroller of the Philippine Navy and was charged alongside nineteen co-accused with estafa through falsification and violations of the Anti-Graft and Corrupt Practices Act.
Background of the Case
- Petitioner was designated by Captain Luisito F. Fernandez to act on his behalf regarding fiscal control activities, including signing disbursement vouchers for procurement purposes.
- On July 2, 1991, six informations were filed against Uy and others for estafa and violation of R.A. No. 3019.
- Following a comprehensive re-investigation ordered by the Sandiganbayan, the Special Prosecutor recommended the withdrawal of estafa charges and instead filed informations for violation of R.A. No. 3019 against a reduced number of accused.
Details of the Charges
- The six amended informations included allegations of gross inexcusable negligence and evident bad faith in handling procurement processes, resulting in a significant overpayment to suppliers.
- Specific documents involved included Abstracts of Canvass, Certificates of Emergency Purc