### Facts:
Herminio T. Disini, the petitioner, faced two charges filed by the Office of the Ombudsman at the Sandiganbayan for his alleged activities during 1974 to February 1986 in Manila, connected to the controversial Philippine Nuclear Power Plant Project in Morong, Bataan. The charges were for corruption of public officials under the Revised Penal Code and a violation under the Anti-Graft and Corrupt Practices Act (R.A. No. 3019). Disini moved to quash the charges, arguing primarily on the grounds of prescription and the jurisdiction of the Sandiganbayan over a private individual like himself. After his motion to quash and subsequent motion for reconsideration were denied by the Sandiganbayan, Disini elevated the matter to the Supreme Court via a petition for certiorari, contending grave abuse of discretion by the Sandiganbayan.
### Procedural History:
The Office of the Ombudsman initially filed the charges against Disini. In response, Disini filed a motion to quash, which was denied. He then submitted himself for arraignment under a plea of not guilty for both charges to pursue permission to travel abroad, which necessitated his arraignment as a prerequisite. After his motion for reconsideration of the quash denial was also dismissed, Disini filed the petition for certiorari with the Supreme Court, raising issues chiefly concerning the jurisdiction of the Sandiganbayan and the applicability of the prescription of the offenses.
### Issues:
1. Whether the Sandiganbayan has jurisdiction over the offenses charged against Disini.
2. Whether the offenses charged against Disini are prescribed.
3. Whether the informations filed against Disini were sufficient in form and substance.
### Court’s Decision:
1. **Jurisdiction**: The Supreme Court affirmed the Sandiganbayan’s jurisdiction over the cases, noting that the offenses charged were within the ambit of cases the Sandiganbayan was empowered to hear, as they were intimately related to the recovery of ill-gotten wealth under Executive Orders affecting the Marcoses and their associates.
2. **Prescription**: The Court ruled that the offenses charged had not prescribed, emphasizing the significance of when the prescriptive period commenced and was interrupted. It applied the principle that the prescriptive period for offenses not immediately known to the State starts from the discovery of the illegal act, not its commission, and highlighted that the proceedings initiated against Disini effectively interrupted the prescriptive period.
3. **Sufficiency of Informations**: The Court held that the informations against Disini sufficiently stated the facts constituting the offenses charged, satisfying the requirements under the Rules of Court for form and substance.
### Doctrine:
This case reiterates the doctrine regarding the jurisdiction of the Sandiganbayan over cases filed pursuant to and in connection with executive orders related to the recovery of ill-gotten wealth, including those involving private individuals closely associated with public officials. It also touches on principles of jurisprudence concerning the prescription of offenses, especially when the State is unaware of the commission of the crime due to the unique circumstances preventing its discovery.
### Class Notes:
– **Jurisdiction of the Sandiganbayan**: Includes cases involving ill-gotten wealth related to the Marcoses and their associates as per relevant Executive Orders.
– **Prescription of Offenses**: The prescription period for crimes begins not at the commission but upon the State’s discovery of the crime if the nature of the offense was concealed by the actions of the offenders.
– **Sufficiency of Informations**: The requirement that informations must allege facts directly constituting the offense; extrinsic matters or evidence are not considered at the quashal stage.
### Historical Background:
This case hails from the tumultuous period of the Marcos regime in the Philippines, specifically relating to corruption and the accumulation of ill-gotten wealth. The controversies surrounding the Philippine Nuclear Power Plant Project exemplify the grave abuses of power and corruption pervasive at the highest levels of government during this era. Disini’s prosecution is part of the broader effort to address and rectify the injustices and malfeasance of the Marcos years, emphasizing the continuing struggle for accountability and justice in the Philippines.
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