People of the Philippines v. Sandiganbayan (Third Division) and Rolando Plaza
**Facts:**
Rolando Plaza, a member of the Sangguniang Panlungsod of Toledo City with salary grade 25, was charged with violating Section 89 of Presidential Decree (P.D.) No. 1445 or The Auditing Code of the Philippines. Plaza received cash advances totaling ₱33,000 on December 19, 1995, which he failed to liquidate as required by law, despite demands to do so. The information alleged that Plaza’s failure to liquidate was with deliberate intent and intent to gain, causing damage to the government.
Plaza filed a Motion to Dismiss on April 7, 2005, challenging the Sandiganbayan’s jurisdiction. The Sandiganbayan ordered the prosecution to submit comments on the motion. On April 19, 2005, the prosecution opposed the motion. However, on July 20, 2005, the Sandiganbayan dismissed the case, stating it lacked jurisdiction based on Plaza’s salary grade being below 27.
The prosecution filed a petition under Rule 45 of the Rules of Court on September 2, 2005, seeking to reverse the Sandiganbayan’s dismissal.
**Issues:**
1. Whether the Sandiganbayan has jurisdiction over public officials with salary grade below 27 when charged with offenses other than those under R.A. 3019, R.A. 1379, or Chapter II, Section 2, Title VII of the Revised Penal Code.
2. The interpretation and application of jurisdictional provisions under P.D. 1606, as amended by R.A. 7975 and R.A. 8249.
**Court’s Decision:**
1. **Jurisdiction of the Sandiganbayan Over Salary Grade Below 27:**
The Supreme Court ruled in favor of the petitioner, stating that the Sandiganbayan indeed has jurisdiction over offenses committed by public officials below salary grade 27, as long as the offense is committed in relation to their office. This interpretation relied heavily on prior cases like People v. Sandiganbayan and Amante and Serana v. Sandiganbayan.
2. **Application of P.D. 1606, as Amended:**
The Court noted that Section 4(b) of P.D. 1606, as amended by R.A. 8249, allows for the prosecution of other offenses committed by public officials and employees in relation to their office, without salary grade limitations. Therefore, the Sandiganbayan’s jurisdiction extends to such cases as long as the offense is connected to the public official’s duties.
**Doctrine:**
– **Jurisdictional Rule:** The Sandiganbayan has jurisdiction over offenses committed by public officials in relation to their office, regardless of their salary grade, provided those officials fall under the enumerated categories.
– **Offense Relation to Office:** An offense is committed in relation to office if it is intimately connected with the office and perpetrated while performing official functions.
**Class Notes:**
– **Key Elements or Concepts:**
– **Jurisdiction of the Sandiganbayan:** Defined under P.D. 1606, as amended by R.A. 7975 and R.A. 8249, particularly Sections 4(a) and 4(b).
– **Public Office Connection:** Offenses committed in relation to the public office delineate jurisdiction; the nature of the crime must relate directly to the official duties.
– **Relevant Legal Statutes:**
– **P.D. No. 1445:** The Auditing Code of the Philippines.
– **P.D. No. 1606, Section 4, as amended by R.A. Nos. 7975 and 8249:** Defines the original jurisdiction of the Sandiganbayan.
– **R.A. No. 3019:** Anti-Graft and Corrupt Practices Act.
– **R.A. No. 1379:** Law on Forfeiture of Ill-gotten Wealth.
– **Interpretation:** Jurisdiction is based on the nature of the offense and its relation to the official function, not solely the salary grade unless explicitly stated.
**Historical Background:**
The case must be viewed in light of the evolving jurisdictional parameters of the Sandiganbayan, established to ensure graft and corruption cases against public officials are effectively and expeditiously handled. The amendments through R.A. 7975 and R.A. 8249 aimed to fine-tune jurisdictional rules for improved clarity and efficacy in adjudicating cases involving public office misconduct.
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