The Supreme Court clarified that the Sandiganbayan has jurisdiction over cases involving members of the Sangguniang Panlungsod (city council) charged with violating the Auditing Code of the Philippines, regardless of their salary grade. This ruling ensures that local officials are held accountable for financial irregularities, reinforcing the integrity of local governance. This decision emphasizes that the Sandiganbayan’s jurisdiction extends to offenses committed in relation to a public official’s office, especially when those officials are among those specifically enumerated in the law, regardless of salary grade.

Toledo City Fiscal Accountability: When Does the Sandiganbayan Have Jurisdiction?

This case, People of the Philippines v. Sandiganbayan and Rolando Plaza, revolves around whether the Sandiganbayan has jurisdiction over a member of the Sangguniang Panlungsod (city council) whose salary grade is below 27 and who is charged with violating the Auditing Code of the Philippines. Respondent Rolando Plaza, a member of the Sangguniang Panlungsod of Toledo City, Cebu, with salary grade 25, was charged with violating Section 89 of Presidential Decree (P.D.) No. 1445, the Auditing Code of the Philippines, for failing to liquidate cash advances amounting to Thirty-Three Thousand Pesos (P33,000.00). The Sandiganbayan initially dismissed the case for lack of jurisdiction, prompting the People of the Philippines to file a petition questioning this dismissal, arguing that the Sandiganbayan’s jurisdiction extends to public officials enumerated under Section 4 (a) (1) of P.D. 1606, as amended by Republic Act (R.A.) Nos. 7975 and 8249, even if they do not occupy positions classified under salary grade 27 and above, particularly when the charges involve crimes committed in relation to their office.

The petitioner contended that the Sandiganbayan has criminal jurisdiction over cases involving specific public officials and employees regardless of their salary grade. These officials are enumerated under Section 4 (a) (1) of P.D. 1606, as amended by R.A. Nos. 7975 and 8249. According to the petitioner, jurisdiction applies whether they are charged with violating R.A. 3019, R.A. 1379, or any felonies included in Chapter II, Section 2, Title VII, Book II of the Revised Penal Code, or for crimes committed in relation to their office. The petitioner also challenged the Sandiganbayan’s interpretation of the Supreme Court’s decision in Inding v. Sandiganbayan, arguing that Inding did not limit the application of Section 4 (a) (1) of P.D. 1606 exclusively to cases involving violations of R.A. 3019, R.A. 1379, or Chapter II, Section 2, Title VII of the Revised Penal Code.

In response, the respondent argued that the Sandiganbayan’s jurisdiction is defined by Section 4 of P.D. 1606, as amended. He claimed that the Sandiganbayan has original jurisdiction only over cases (a) where the accused is a public official with salary grade 27 and higher, or (b) where the accused is a public official below grade 27 but holds a position mentioned in Section 4 (a) (1) (a) to (g) of P. D. 1606, as amended, and the offense involves a violation of R.A. 3019, R.A. 1379, or Chapter II, Section 2, Title VII of the Revised Penal Code. According to the respondent, in cases involving other offenses, the general rule requiring a salary grade of 27 and higher must apply for the Sandiganbayan to exercise jurisdiction.

To resolve this issue, the Supreme Court turned to the provisions of P.D. 1606, as amended by R.A. 7975 and R.A. 8249. These laws define the jurisdiction of the Sandiganbayan, particularly concerning offenses committed by public officials. The Court emphasized that the jurisdiction to try a criminal case is determined at the time the action is instituted, not when the offense was committed. This principle is especially pertinent in this case, where the offense occurred in 1995, and the information was filed in 2004, making R.A. 8249 the applicable law.

The Court referenced its earlier ruling in People v. Sandiganbayan and Amante, a case with similar facts, where the respondent was also a member of the Sangguniang Panlungsod of Toledo City, Cebu. The key provision at issue was Section 4 of P.D. 1606, as amended by R.A. 8249, which specifies the Sandiganbayan’s jurisdiction over cases involving violations of R.A. No. 3019, R.A. No. 1379, and Chapter II, Section 2, Title VII of the Revised Penal Code. Crucially, the Court also considered Section 4 (b), which extends the Sandiganbayan’s jurisdiction to:

B. Other offenses or felonies, whether simple or complexed with other crimes committed by the public officials and employees mentioned in subsection (a) of this section in relation to their office.

The Court interpreted this provision to mean that other offenses or felonies committed by public officials mentioned in subsection (a) in relation to their office also fall under the Sandiganbayan’s jurisdiction. This interpretation is critical because it broadens the scope of the Sandiganbayan’s authority beyond just the specific offenses enumerated in Section 4 (a).

Analyzing the interplay between Section 4(a) and 4(b), the Court highlighted a key distinction. While Section 4(a) lists specific offenses requiring a particular rank for jurisdiction, Section 4(b) encompasses other offenses related to the official’s duties. This distinction is crucial, as offenses under Section 4(a) require public office as an essential element, while offenses under Section 4(b) only need to be committed in relation to the public official’s office. The Supreme Court, citing Rodriguez, et al. v. Sandiganbayan, et al., clarified that for an offense to be considered “committed in relation” to the accused’s office:

as long as the offense charged in the information is intimately connected with the office and is alleged to have been perpetrated while the accused was in the performance, though improper or irregular, of his official functions, there being no personal motive to commit the crime and had the accused not have committed it had he not held the aforesaid office, the accused is held to have been indicted for “an offense committed in relation” to his office.

In essence, this means that if the crime is closely linked to the official’s duties and was committed while performing those duties, it falls under the Sandiganbayan’s jurisdiction, regardless of whether the official’s position is explicitly mentioned under Section 4(a). This interpretation ensures that public officials cannot evade accountability by arguing that their specific position is not covered by the law, as long as the crime is connected to their official functions.

The Court found that the violation of the Auditing Code of the Philippines by Plaza was indeed related to his office as a member of the Sangguniang Panlungsod. Consequently, the Sandiganbayan had original jurisdiction over the case. The Supreme Court also addressed the Sandiganbayan’s reliance on the Inding case, clarifying that Inding did not limit the application of Section 4 (a) (1) exclusively to cases involving violations of R.A. 3019, R.A. 1379, or Chapter II, Section 2, Title VII of the Revised Penal Code. The Court emphasized that the enumeration in Section 4(a) does not preclude the application of Section 4(b) to other offenses committed in relation to the public official’s office.

To summarize, the Supreme Court’s decision underscores the Sandiganbayan’s broad jurisdiction over public officials who commit offenses related to their office. The ruling clarifies that specific enumeration in Section 4(a) does not restrict the application of Section 4(b), ensuring that officials cannot escape accountability based on technicalities related to their position or salary grade. This case is critical for understanding the scope of the Sandiganbayan’s authority and its role in prosecuting corruption and other offenses committed by public officials in the Philippines.

FAQs

What was the key issue in this case?	The key issue was whether the Sandiganbayan has jurisdiction over a member of the Sangguniang Panlungsod (city council) with a salary grade below 27 who is charged with violating the Auditing Code of the Philippines.
What is Section 4 of P.D. 1606?	Section 4 of Presidential Decree No. 1606, as amended, defines the jurisdiction of the Sandiganbayan, specifying which cases it has the authority to hear and decide. It outlines the types of offenses and the positions of public officials that fall under its jurisdiction.
What is the significance of Section 4(b) of P.D. 1606?	Section 4(b) extends the Sandiganbayan’s jurisdiction to other offenses or felonies committed by public officials mentioned in Section 4(a) in relation to their office. This ensures that officials cannot evade prosecution for crimes connected to their official duties, even if those crimes are not specifically enumerated.
What did the Supreme Court rule in this case?	The Supreme Court ruled that the Sandiganbayan does have jurisdiction over members of the Sangguniang Panlungsod charged with violating the Auditing Code of the Philippines, regardless of their salary grade, if the offense was committed in relation to their office.
How does this ruling affect local government officials?	This ruling holds local government officials accountable for financial irregularities and ensures that they cannot evade prosecution by claiming their position is not covered by the Sandiganbayan’s jurisdiction. It reinforces the importance of integrity and accountability in local governance.
What was the Inding v. Sandiganbayan case?	Inding v. Sandiganbayan is a previous Supreme Court case that was interpreted by the Sandiganbayan to limit its jurisdiction. The Supreme Court clarified in this case that Inding did not constrict the application of Section 4 (a) (1) of P.D. 1606 exclusively to specific offenses.
What is the Auditing Code of the Philippines?	The Auditing Code of the Philippines, or Presidential Decree No. 1445, establishes rules and regulations for auditing government funds and properties. It aims to ensure transparency, accountability, and proper management of public resources.
What does ‘committed in relation to office’ mean?	An offense is considered ‘committed in relation to office’ if it is intimately connected with the public official’s duties and was perpetrated while performing those duties, even if improperly or irregularly. This means the office was a factor in the commission of the crime.

This Supreme Court decision reinforces the importance of accountability among local government officials, ensuring that the Sandiganbayan has the jurisdiction to prosecute those who violate the Auditing Code of the Philippines in connection with their official duties. By clarifying the scope of the Sandiganbayan’s authority, the ruling promotes transparency and integrity in local governance, preventing officials from evading justice on technical grounds.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Sandiganbayan, G.R. No. 169004, September 15, 2010