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LACSON VS.

EXECUTIVE SECRETARY
301 SCRA 298
Facts:
Eleven persons believed to be members of the Kuratong Baleleng
gang, an organized crime syndicate involved in bank robberies, were slain by
elements of the Anti-Bank Robbery and Intelligence Task Group (ABRITG).
Among those included in the ABRITG were petitioners and petitionerintervenors. Twenty-six respondents including herein petitioner, charged as
principal, and herein petitioner-intervenors, charged as accessories were
indicted for multiple murder. After a reinvestigation, the Ombudsman filed
amended informations before the Sandiganbayan, where petitioner was
charged
only
as
an
accessory.
The accused filed separate motions questioning the jurisdiction of the
Sandiganbayan, asserting that under the amended informations, the cases
fall within the jurisdiction of the Regional Trial Court pursuant to Section 2 of
R.A. 7975. They contend that the said law limited the jurisdiction of the
Sandiganbayan to cases where one or ore of the principal accused are
government officals with Salary Grade 27 or higher, or PNP officials with rank
of Chief Superintendent or higher. Thus, they did not qualify under said
requisites. However, pending resolution of their motions, R.A. 8249 was
approved amending the jurisdiction of the Sandiganbayan by deleting the
word principal from the phrase principal accused in Section 2 of R.A.
7975. It is due to this deletion of the word "principal" that the parties herein
are at loggerheads over the jurisdiction of the Sandiganbayan.
Issue:
Whether or not the Sandiganbayan has jurisdiction over the subject
criminal cases.
Held:
Yes. Section 4 of R.A. 8249 reveals that to fall under the exclusive
original jurisdiction of the Sandiganbayan, the following requisites must
concur, among others: (1) the offense committed is a violation of (a) R.A.
3019, as amended (the Anti-Graft and Corrupt Practices Act), (b) R.A. 1379
(the law on ill-gotten wealth), (c) Chapter II, Section 2, Title VII, Book II of the
Revised Penal Code (the law on bribery). Considering that herein petitioner
and intervenors are being charged with murder which is a felony punishable
under Title VIII of the Revised Penal Code, the governing on the jurisdictional
offense is paragraph b, Section 4 of R.A. 8249 which pertains to "other
offenses or felonies whether simple or complexed with other crimes
committed by the public officials and employees mentioned in subsection a
of (Section 4, R.A. 8249) in relation to their office. Thus, under said
paragraph b, what determines the Sandiganbayan's jurisdiction is the official
position or rank of the offender that is, whether he is one of those public

officers or employees enumerated in paragraph a of Section 4. The offenses


mentioned in pargraphs a, b and c of the same Section 4 do not make any
reference to the criminal participation of the accused public officer as to
whether he is charged as a principal, accomplice or accessory. In enacting
R.A. 8249, the Congress simply restored the original provisions of P.D. 1606
which does not mention the criminal participation of the public officer as a
requisite to determine the jurisdiction of the Sandiganbayan.
REODICA VS. CA
292 SCRA 87

Facts:
Isabelita Reodica was allegedly recklessly driving a van and hit Bonsol
causing him physical injuries and damage to property amounting to P 8,542.00.
Three days after the accident a complaint was filed before the fiscals office against
the petitioner. She was charged of "Reckless Imprudence Resulting in Damage to
Property with Slight Physical Injury." After pleading not guilty trial ensued. RTC of
Makati rendered the decision convicting petitioner of "quasi offense of reckless
imprudence, resulting in damage to property with slight physical injuries"
with arresto mayor of 6 months imprisonment and a fine of P 13,542.00. Petitioner
made an appeal before the CA which re-affirmed the lower courts decision. In its
motion for reconsideration, petitioner now assails that (1) the court erred in giving
its penalty on complex damage to property and slight physical injuries both being
light offenses over which the RTC has no jurisdiction and it cant impose penalty in
excess to what the law authorizes, and (2) reversal of decision is still possible on
ground of prescription or lack of jurisdiction.
Issue:
Whether or not RTC of Makati has jurisdiction over the quasi offenses in
question.
Held:
Negative. The jurisdiction to try a criminal action is to be determined by the
law in force at the time of the institution of the action, unless the statute expressly
provides, or is construed to the effect that it is intended to operate as to actions
pending before its enactment.
At the time of the filing of the information in this case, the law in force was
Batas Pambansa Blg. 129, otherwise known as The Judiciary Reorganization Act of
1980. Section 32(2) thereof provided that except in cases falling within the
exclusive original jurisdiction of the Regional Trial Courts and of the Sandiganbayan,
the Metropolitan Trial Courts (MeTCs), Municipal Trial Courts (MTCs), and Municipal
Circuit Trial Courts (MCTCs) had exclusive original jurisdiction over all offenses
punishable with imprisonment of not exceeding four years and two months, or a fine
of not more than four thousand pesos, or both fine and imprisonment, regardless of
other imposable accessory or other penalties, including the civil liability arising from
such offenses or predicated thereon, irrespective of kind, nature, value or amount
thereof.

Since offenses punishable by imprisonment of not exceeding 4 years and 2


months were within the jurisdictional ambit of the MeTCs, MTCs and MCTCs, it
follows that those penalized with censure, which is a penalty lower than arresto
menor under the graduated scale in Article 71 of the Revised Penal Code and with a
duration of 1 to 30 days, should also fall within the jurisdiction of said courts. Thus,
reckless imprudence resulting in slight physical injuries was cognizable by said
courts.
As to the reckless imprudence resulting in damage to property in the amount
of P8,542.00, the same was also under the jurisdiction of MeTCs, MTCs or MCTCs
because the imposable penalty therefor was arresto mayor in its minimum and
medium periods -- the duration of which was from 1 month and 1 day to 4 months.
Criminal Case No. 33919 should, therefore, be dismissed for lack of jurisdiction
on the part of the RTC of Makati.

BONDOC VS. SANDIGANBAYAN


G.R. No. 71163-65, November 9, 1990

Facts:
Bondoc and Vicente, private individuals, were charged with several
felonies of estafa thru falsification of public documents as principals by
indispensable cooperation with employees of the Central Bank, and other
private individuals. However, Bondoc and Vicente were not investigated and
indicted until long after the criminal proceedings against their co-principals
had commenced, and the latter's cases had already been submitted for
decision when Bondoc's and Vicente's own cases came up for trial. Bondoc
moved to quash the informations on January 3, 1985 on the basic theory that
as a private individual charged as co-principal with government employees,
he should be tried jointly with the latter pursuant to Section 4 (paragraph 3)
of PD 1606, as amended, supra; hence, the separate proceedings
commenced against him were invalid, for lack of jurisdiction of the
Sandiganbayan over the offenses and his person. The Third Division of
Sandiganbayan denied Bondocs motion to quash, hence this petition for
reconsideration.
Issue:
Whether or not the Sandiganbayan lost jurisdiction over Bondoc's
cases for its failure to try jointly his cases with public officers or employees,
and whether or not, as a consequence, those cases became cognizable by
the regular courts and should be transferred thereto for trial and
adjudgment.

Held:
No. The seeming impossibility of a joint trial cannot and does not alter
the essential nature of the crimes in question, as felonies perpetrated by
public officers or employees in confabulation with private persons. Assuming
it is correct to construe the law in a strictly literal sense, the indicated course
of action would be to insist on holding a joint trial regardless of whatever
circumstances may appear to make such a joint trial inappropriate,
inconvenient, unfeasible. Thus, for instance, the cases in the Second
Division, although already submitted for decision, should be reopened to
allow for the consolidation of Bondoc's cases with those of the defendants
therein, and the reception of evidence against and for Bondoc. Indeed, even
in the extreme hypothesis of appeal having already been taken by Bondoc's
co-accused, the course of action dictated by a literal construction of the
provision on joint trial is the remand of the appealed case to the
Sandiganbayan so that the joint trial may be conducted. To construe the law
in the manner indicated, however, would be unreasonable, if not absurd, and
settled is the rule that courts should not give a statute a meaning that would
lead to absurdities
Furthermore, it is not legally possible to transfer Bondoc's cases to the
Regional Trial Court, for the simple reason that the latter would not have
jurisdiction over the offenses. These crimes are within the exclusive, original
jurisdiction of the Sandiganbayan. They simply cannot be taken cognizance
of by the regular courts, apart from the fact that even if the cases could be
so transferred, a joint trial would nonetheless not be possible.
PEOPLE VS RAMOS
207 SCRA 144
Facts:
Pending criminal cases in the MCTC of Ilocus Sur were instituted without the
intervention of the Provincial Prosecutor but the assistant prosecutor participated in
one of these cases. Upon his death he was not replaced due to alleged
undermanned office of Provincial Prosecutor Cabebe. Cabebe informed Judge
Ranches about this matter and asked him to allow the offended parties or peace
officers to handle the prosecution of these cases. Judge Ranches rejected his
request which was also sustained by Judge Ramos upon appeal in the RTC of Vigan.
In the second case, Judge Vizcarra postponed the trial of the pending criminal
case and ordered for the attendance of Cabebe or any of his assistance to prosecute
the case. Despite the claim of Cabebe that his office was understaffed and that the
case was already handled by a private practitioner under his authority and that
Cabebe already informed the court the circumstances why his office was
understaffed.
Issue:
(1) Whether or not the judge is allowed to interfere with the administration of

the office of the Provincial Prosecutor.


(2) Whether or not the contention of the petitioners are tenable (Since the
office of the Provincial Prosecutor is understaffed the peace officers should
be allowed to handle the prosecution of the cases.)
Held:
(1) Yes, the judge can interfere pursuant to the clear directive of the law. The
argument of the petitioners that the respondent judges should not be
allowed to interfere with the administration of the Office of the Provincial
Prosecutor is not acceptable. In requiring that office to prosecute the
cases before them, the said respondent judges were merely enforcing the
basic rule in Section 5 that "all criminal actions either commenced by
complaint or information shall be prosecuted under the direction and
control of the fiscal." The questioned orders were in fact based, albeit
unwittingly, on the directive of the Department of Justice.
(2) No, the contention is not tenable. The Court feels that in those cases
where the prosecutors themselves have filed the criminal charges, there is
all the more reason for them to actively intervene in their prosecution.
Having presumably made the necessary investigation of these cases
before filing the corresponding informations, they are in the best position
to handle their prosecution on the basis of their initial findings. If the
prosecutor had not determined the prima facie guilt of the accused, he
should not have filed the information in the first place. At any rate, there
is something not quite correct in the prosecutor filling the information
himself and then leaving the offended party in the lurch, as it were, by
asking him to fend for himself in prosecuting the case.

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