People vs. Montejo, 108 Phil. 613 FACTS: Mayor Leroy Brown of Basilan City and several detectives were char charge ged d wi with th murd murder er for for th the e ki kill llin ing g of Yakan akan Awali walin n Teag eag!! Mayor Brown ordered his men to arrest and detain Teag! "e was also su#ected to severe torture during the course of his investigation held at a $olice sustation which later resulted to his death! The Mayor and his men then rought him to a neary isolated %eld to make it a$$ear that Teag Teag had een killed during an encounte e ncounterr! &SS'(: )as the o*ense committed in relation to their $ulic o*ice+ ,(C&S&-.: Y(S! The o*ense was committed in relation to their $ulic o*ice! )hile $ulic o*ice is not an element of the crime of murder/ the o*ense charged in the amended information is intimately connected wi with th th thei eirr res$ res$ec ecti tive ve o*ic o*ices es and and was was $er$ $er$et etra rate ted d while ile th they ey were ere in the $erfo erforrmanc mance/ e/ thoug hough h im$ro m$ro$e $err or irregular/ of their o*icial functions! &ndeed/ they had no $ersonal motive to commit the crime and they would not have committed it had they not held their aforesaid o*ices! The co0defendants of Mayo Mayorr Br Brow own n oeye oeyed d hi his s in inst stru ruct ctio ions ns eca ecaus use e he was was th their eir su$erior o*icer as Mayor of Basilan City!
Sanchez vs. Demetriou, 207 S!" 627 FACTS: Mayor Sanche1 of Calauan/ Laguna was charged for the crime of ra$e with homicide for the ra$e0slay of Mary (ileen Sarmenta and the killing of Allan 2ome1! The information against him was %led with the 3egional Trial Court! Mayor Sanche1 moves to 4uash the information on the ground that as the incument Mayor at the time of the alleged commission of the crime/ his case should only e tried under the #urisdiction of Sandiganayan/ and not of the regular courts! The law $rovides that the Sandiganayan shall e5ercise e5clusive original #urisdiction over 678 graft and corru$tion cases and 698 o*enses committed in relation to the ofice o the petitioner ! &SS'(: ,oes the 3egional Trial Court have #urisdiction in his case+ ,(C&S&-.: Y(S! The case should e tried under the 3TC and not Sandiganayan! The case of Mayor Sanche1 was .-T considered in relation to his $ulic o*ice! &n the case at ar/ there is no direct relation etween the commission of the crime of ra$e with homicide and Mayor Sanche1s o*ice ecause public ofice is not an essential element of the crime charged! The o*ense can stand inde$endently of the o*ice! Moreover/ it is not even alleged in the information that the commission of the crime charged was intimately connected with the $erformance of the $etitioners o*icial functions!
#acson vs. $%ecutive Secretar&, 301 S!" 2'8 FACTS: ;etitioners Chief Su$erintendent ;an%lo Lacson and other $olice o*icers were charged as <$rinci$al accused= in eleven 6778 informations for multi$le murder efore the Sandiganayan for the killing of eleven 6778 $ersons/ who are alleged memers of the Kuratong Baleleng gang! &n the amended informations/ Lacson and others were later charged as
?>@ 6old Sandiganayan law8 ecause the law limits the #urisdiction of the Sandiganbayan to cases where the $rinci$al accused= has the rank of Chief Su$erintendent or higher! The cases were transferred to the 3egional Trial Court since none of the $rinci$al accused has the rank of Chief Su$erintendent or higher! )hen 3A 9?/ de%ning and e5$anding the SandiganayanDs #urisdiction/ was a$$roved into law/ the Sandiganayan declared that it has #urisdiction to try and decide o*enses committed y $ulic o*icers in relation to their o*ice! &SS'(:
,oes the Sandiganayan have #urisdiction in this case+ ,(C&S&-.: .-! The case is within the e5clusive original #urisdiction of the 3egional Trial Court/ not the Sandiganayan ecause the amended informations ailed to show that the o*ense was intimately connected with the discharge of o*icial functions of the accused ;.; o*icers! )hile the information states that the crime of murder was committed
orpuz vs. (ano)*a&an, "pril 2+, 1'87 FACTS: ;etitioners .atividad Cor$u1 and several C-M(L(C o*icials were charged with violation of the 7?> (lection Code for electioneering and cam$aigning inside the voting centers during the election! The com$laint was initially %led efore the Commission on (lections 6C-M(L(C8! The C-M(L(C then conducted a formal investigation ut later dismissed the com$laint for insu*iciency of evidence! The com$laint was re%led with the Tanodayan and the latter started a $reliminary investigation! ;etitioners moved for the dismissal of the com$laint ut were denied y the Tanodayan as it asserts e5clusive authority to $rosecute the case! The Tanodayan also
contends that only the Sandiganayan has #urisdiction over o*enses committed y $ulic o*icers and em$loyees in relation to their o*ice! &SS'(: ,oes the Sandiganayan have #urisdiction over election o*enses committed y a $ulic o*icer in relation to his o*ice+ ,(C&S&-.: .-! 'nder the Constitution and 7?> (lection Code/ it is the C-M(L(C/ not the Tanodayan or Sandiganayan which has the e5clusive #urisdiction to investigate and $rosecute election ofenses committed y any $erson/ whether $rivate individual or $ulic o*icer or em$loyee/ and irres$ective of whether the o*ense is committed in relation to his o*icial duties or not! &n other words/ it is the nature of the o*ense and not the $ersonality of the o*ender that matters! As long as the o*ense is an election ofense/ #urisdiction over the same rests e5clusively with the C-M(L(C/ in view of its all0emracing $ower over the conduct of elections!
on)oc vs. San)i-an*a&an, ovem*er ', 1''0 FACTS:
Two government em$loyees of the Central Bank 6now Bangko Sentral ng ;ili$inas8 and several $rivate individuals were charged with several counts of estafa thru falsi%cation of $ulic documents %led efore the Sandiganayan! The cases were assigned in the Second ,ivision of the Sandiganayan! Two years later/ Carlito Bondoc who was an Assistant Manager of C&T&BA.E and another $rivate individual/ were charged as co0 $rinci$als y indis$ensale coo$eration due to their alleged cons$iracy with the government em$loyees! The case was assigned to the Third ,ivision of the Sandiganayan! The Third ,ivision later referred BondocDs case to the Second ,ivision to consolidate it with the case against the government em$loyees! But it turned out that the case against the government em$loyees has already een terminated leaving BondocDs case on its own! The Sandiganayan then seeks to try Bondoc se$arately from the government em$loyees! Bondoc argues that as a $rivate individual charged as co0$rinci$al with the government em$loyees/ the law re4uires that he should e tried #ointly with the government em$loyees involved in the same o*enses! Since a #oint trial was then already im$ossile/ the Sandiganayan cannot e5ercise #urisdiction over his case! &SS'(: ,oes the Sandiganayan still have #urisdiction even if #oint trial is no longer feasile+ ,(C&S&-.: Y(S! These crimes are still within the e5clusive/ original #urisdiction of the Sandiganayan since the crimes charged are o*enses or felonies committed y $ulic o*icers and em$loyees in relation to their o*ice/ in confaulation and cons$iracy with Bondoc and other $rivate $ersons! ;rivate individuals accused in the Sandiganayan must e tried #ointly together with the $ulic o*icer unless the attendant circumstances have made im$ossile or im$racticale such a #oint trial/ as in the cases at ar/ in which event the trial of said
$rivate $ersons may $roceed se$arately from the $ulic o*icers or em$loyees whose own trials have een concluded! The inaility of the Sandiganayan to hold a #oint trial of BondocDs cases and those of the government em$loyees se$arately charged for the same crimes/ has not altered the nature of the o*enses charged committed y government em$loyee in cons$iracy with $rivate $ersons/ including Bondoc! "zarcon vs. San)i-an*a&an, 268 S!" 7/7 FACTS: ;etitioner A1arcon/ a $rivate usinessman involved in earth0 moving usiness/ was in $ossession of an &su1u dum$ truck owned y aime Ancla! &t turned out that aime Ancla was a delin4uent ta5$ayer! So/ the Bureau of &nternal 3evenue sei1ed AnclaDs $ro$erties to satisfy his ta5 liailities! "owever/ A1arcon was later authori1ed y the B&3 to kee$ the dum$ truck since he voluntarily o*ered to act as its custodian! )hen Ancla surre$titiously took away the dum$ truck from A1arconDs custody/ A1arcon was then charged and later found guilty efore the Sandiganayan with the crime of malversation of $ulic funds or $ro$erty under the 3evised ;enal Code 63;C8 for allowing accused Ancla to withdraw the &su1u dum$ truck from his custody! A1arcon contends that the Sandiganayan has no #urisdiction over him since he is not a $ulic o*icer! &SS'(: ,oes the Sandiganayan have #urisdiction over a $rivate individual like A1arcon+ ,(C&S&-.: .-! The Sandiganayan does not have the #urisdiction over him! The Sandiganayan will only have #urisdiction over a $rivate individual when the com$laint charges the $rivate individual either as a co0$rinci$al/ accom$lice or accessory of a $ulic o*icer or em$loyee who has een charged with a crime within its
#urisdiction! The com$laint/ in this case/ does not charge A1arcon as such! Thus/ unless A1arcon is $roven a $ulic o*icer/ the Sandiganayan will have no #urisdiction over the crime charged! "ence/ the ,ecision rendered y Sandiganayan/ are null and void for lack of #urisdiction!
