### Facts:
The case stemmed from several criminal charges filed against Rufino V. Nuñez in 1979 before the Sandiganbayan, a special court established through Presidential Decree (PD) No. 1486 as amended by PD No. 1606. Nuñez was accused of estafa through falsification of public and commercial documents in connivance with other public officials. Upon his arraignment, Nuñez filed a motion to quash the charges on constitutional and jurisdictional grounds, which the Sandiganbayan subsequently denied. Nuñez’s motion for reconsideration was likewise rejected, prompting him to elevate the matter to the Supreme Court through a petition for certiorari and prohibition. Nuñez argued that PD No. 1486 creating the Sandiganbayan was violative of the due process, equal protection, and ex post facto clauses of the Constitution.
### Issues:
1. Whether PD No. 1486, as amended by PD No. 1606 creating the Sandiganbayan, violates the Constitution’s due process and equal protection clauses.
2. Whether the said PD constitutes an ex post facto law as applied to Nuñez’s case.
### Court’s Decision:
The Supreme Court dismissed Nuñez’s petition, upholding the constitutionality of the Sandiganbayan’s creation and its jurisdiction over his case. The Court found that:
1. The classification and creation of a special court like the Sandiganbayan, aimed at addressing corruption among public officials, do not violate the constitutional guarantee of equal protection as they are based on substantial distinctions directly related to a legitimate governmental objective.
2. The concerns over the due process rights were unfounded as Nuñez was given the opportunity to defend himself in a competent court through an orderly procedure.
3. The Sandiganbayan’s establishment and the provisions limiting appeals to questions of law do not constitute an ex post facto law, as they do not make an innocent act criminal, aggravate a crime or its punishment, nor change the rules of evidence to convict the accused.
### Doctrine:
The creation of the Sandiganbayan as a special court with jurisdiction over criminal and civil cases involving graft and corrupt practices committed by public officers does not violate the due process, equal protection, nor the ex post facto clause of the Constitution. The classification justifying the creation of such a court, aimed at curtailing official corruption, is considered reasonable and serves a legitimate governmental purpose.
### Class Notes:
– **Due Process**: Requires that an accused be informed of the charges, tried in a competent court, and conviction based on evidence that meets the required standard.
– **Equal Protection**: Dictates that all individuals under similar circumstances be treated in the same manner by the law, allowing classification if it is reasonable and serves a legitimate purpose.
– **Ex Post Facto Law**: Constitutional prohibition against laws that retroactively change the legal consequences of actions.
**Relevant Statutory Provisions:**
– PD No. 1486 and PD No. 1606: Presidential Decrees creating and amending the charter of the Sandiganbayan.
### Historical Background:
The anti-graft court, Sandiganbayan, was established in response to the growing concern over official corruption and abuse of position by public officers. Through the 1973 Constitution and subsequent Presidential Decrees, the Philippine government aimed to provide a legal mechanism to swiftly and effectively handle crimes involving graft and corruption, ensuring that public office would be a public trust adhered to by all officials.
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