### Facts:
The case began when an Information was filed against Ernesto Navallo on 11 May 1978 for violating Article 217, paragraph 4, of the Revised Penal Code by misappropriating government funds amounting to P16,483.62 as the Collecting and Disbursing Officer of Numancia National Vocational School. Despite the issuance of a warrant and two alias warrants, Navallo was elusive until his arrest on 15 November 1984. He subsequently posted bail. On 18 July 1985, despite already being under the jurisdiction of the Sandiganbayan due to the effectiveness of Presidential Decree No. 1606 as of 10 December 1978, Navallo was arraigned by the RTC and pleaded not guilty. The prosecution moved the case to the Sandiganbayan on 22 May 1986, where a struggle over jurisdiction and the validity of arraignment ensued, leading to Navallo’s plea of “not guilty” on 20 October 1989 in the Sandiganbayan. Navallo argued the Sandiganbayan’s lack of jurisdiction and pleaded double jeopardy, alongside claims of insufficient evidence of guilt and violation of custodial investigation rights.
### Issues:
1. Did the Sandiganbayan have jurisdiction over Navallo despite the initial filing of the case with the RTC prior to the creation of the Sandiganbayan?
2. Did double jeopardy occur due to Navallo’s arraignment at the RTC?
3. Was Navallo’s right under custodial investigation violated when he signed the audit report?
4. Was the evidence against Navallo sufficient for his conviction of malversation beyond reasonable doubt?
### Court’s Decision:
1. **Jurisdiction**: The Supreme Court affirmed that the Sandiganbayan had jurisdiction over the case as it involved a crime by a public officer under Title VII of the Revised Penal Code, fitting the mandates of Presidential Decree No. 1606. Despite earlier proceedings, lack of prior arraignment at the time of PD 1606’s effectivity transferred jurisdiction to the Sandiganbayan.
2. **Double Jeopardy**: The Supreme Court found that double jeopardy did not occur as the RTC was without jurisdiction post PD 1606, and no conviction or acquittal had been made there.
3. **Custodial Investigation Right**: Navallo’s signing of the audit report did not constitute a custodial investigation scenario. Therefore, his rights under such a context were not violated.
4. **Sufficiency of Evidence**: The Supreme Court agreed with the Sandiganbayan’s findings, citing the legal presumption of malversation applied due to Navallo’s inability to account for the missing funds. The Court also found Navallo’s defenses implausible and unconvincing.
### Doctrine:
The decision reiterated the presumption of malversation under Article 217 of the Revised Penal Code, which holds an accountable officer’s failure to account for public funds as prima facie evidence of misappropriation. It also confirmed that jurisdiction for crimes by public officers under Title VII of the RPC lies exclusively with the Sandiganbayan following PD 1606, and clarified the non-applicability of custodial investigation rights in audit situations.
### Class Notes:
– **Malversation of Public Funds**, as defined in Article 217 of the Revised Penal Code, can be established by demonstrating an accountable officer’s inability to account for public funds or property, creating a presumption of misappropriation.
– **Jurisdiction**: The creation of the Sandiganbayan through PD 1606 transferred jurisdiction over crimes committed by public officers from RTCs to the Sandiganbayan, conditional on the lack of arraignment prior to PD 1606’s effectivity.
– **Double Jeopardy**: Requires a valid charge, jurisdiction, arraignment, and conviction/acquittal or dismissal without the defendant’s consent. It does not apply if the court of first instance lacked jurisdiction.
– **Custodial Investigation Rights** are applicable only during custodial investigation by law enforcement officers, not during audit examinations by audit officers.
### Historical Background:
This case falls within the purview of actions taken to specialization and jurisdictional refinement in the Philippine judicial system, specifically highlighting the transition of jurisdiction from traditional courts (CFI/RTC) to specialized tribunals (Sandiganbayan) following the creation of the latter to handle corruption and crimes committed by public officials as part of wider legal reforms under the Marcos administration.
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