G.R. No. 133535 – 372 Phil. 816 – 320 SCRA 684 – Criminal Law – Crimes Committed by Public Officers – Plunder; Jurisdiction
Remedial Law – Jurisdiction of Courts – Jurisdiction of the Sandiganbayan
In 1996, an Information was filed with the Sandiganbayan against Lilia Organo for the crime of plunder as it was alleged that she and some other government officials stole P193 million from the government.
Organo filed a motion to quash alleging that the Sandiganbayan has no jurisdiction over the case pursuant to Republic Act No. 8249 which provides that the Sandiganbayan has no jurisdiction over government employees who do not have a salary grade of Salary Grade 27. Organo was able to prove that her position in the Bureau of Internal Revenue is below Salary Grade 27.
The Sandiganbayan denied her motion. It insisted that under the Plunder Law (Republic Act No. 7080, as amended), the Sandiganbayan was vested with the jurisdiction over plunder cases and since RA 8249 is a general law and that RA 7080 is a special law, RA 7080 should prevail.
ISSUE: Whether or not the Sandiganbayan can try plunder cases where the accused is below Salary Grade 27.
HELD: No. The Plunder Law itself provides:
Until otherwise provided by law, all prosecutions under this Act shall be within the original jurisdiction of the Sandiganbayan.
The Sandiganbayan only had provisional jurisdiction over all plunder cases. In 1997, when RA 8249 was passed which further defined the jurisdiction of the Sandiganbayan, there is already no question as to which plunder cases are within the exclusive jurisdiction of the Sandiganbayan. The said law finally prescribed that the Sandiganbayan has no jurisdiction over government employees which are below Salary Grade 27. RA 8249 is a special law the intention of which was to declog the dockets of the Sandiganbayan. As such, the Sandiganbayan has no jurisdiction over Organo. The case should be filed in the appropriate court.
