MARY GRACE L.

RENON BL 3
Criminal Procedures

LACSON VS. EXECUTIVE SECRETARY

301 SCRA 298
Facts:
Eleven persons believed to be members of the Kuratong Baleleng gang,
an organized crime syndicate involved in bank robberies, were slain by elements of the Anti-Bank
Robbery and Intelligence Task Group (ABRITG). Among those included in the ABRITG were
petitioners and petitioner-intervenors. Twenty-six respondents including herein petitioner,
charged as principal, and herein petitioner-intervenors, charged as accessories were indicted for
multiple murder. After a reinvestigation, the Ombudsman filed amended informations before the
Sandiganbayan,
where
petitioner
was
charged
only
as
an
accessory.
The accused filed separate motions questioning the jurisdiction of the Sandiganbayan, asserting
that under the amended informations, the cases fall within the jurisdiction of the Regional Trial
Court pursuant to Section 2 of R.A. 7975. They contend that the said law limited the jurisdiction
of the Sandiganbayan to cases where one or ore of the principal accused are government
officals with Salary Grade 27 or higher, or PNP officials with rank of Chief Superintendent or
higher. Thus, they did not qualify under said requisites. However, pending resolution of their
motions, R.A. 8249 was approved amending the jurisdiction of the Sandiganbayan by deleting
the word principal from the phrase principal accused in Section 2 of R.A. 7975. It is due to
this deletion of the word "principal" that the parties herein are at loggerheads over the
jurisdiction of the Sandiganbayan.
Issue:
Whether or not the Sandiganbayan has jurisdiction over the subject criminal cases.
Held:
Yes. Section 4 of R.A. 8249 reveals that to fall under the exclusive original jurisdiction of
the Sandiganbayan, the following requisites must concur, among others: (1) the offense
committed is a violation of (a) R.A. 3019, as amended (the Anti-Graft and Corrupt Practices Act),
(b) R.A. 1379 (the law on ill-gotten wealth), (c) Chapter II, Section 2, Title VII, Book II of the Revised
Penal Code (the law on bribery). Considering that herein petitioner and intervenors are being
charged with murder which is a felony punishable under Title VIII of the Revised Penal Code, the
governing on the jurisdictional offense is paragraph b, Section 4 of R.A. 8249 which pertains to
"other offenses or felonies whether simple or complexed with other crimes committed by the
public officials and employees mentioned in subsection a of (Section 4, R.A. 8249) in relation to
their office. Thus, under said paragraph b, what determines the Sandiganbayan's jurisdiction is
the official position or rank of the offender that is, whether he is one of those public officers
or employees enumerated in paragraph a of Section 4. The offenses mentioned in pargraphs a, b
and c of the same Section 4 do not make any reference to the criminal participation of the
accused public officer as to whether he is charged as a principal, accomplice or accessory. In
enacting R.A. 8249, the Congress simply restored the original provisions of P.D. 1606 which does
not mention the criminal participation of the public officer as a requisite to determine the
jurisdiction of the Sandiganbayan.

MARY GRACE L. RENON BL 3

Criminal Procedures
REODICA VS. CA
292 SCRA 87
Facts:
Isabelita Reodica was allegedly recklessly driving a van and hit Bonsol causing him physical injuries
and damage to property amounting to P 8,542.00. Three days after the accident a complaint was filed
before the fiscals office against the petitioner. She was charged of "Reckless Imprudence Resulting
in Damage to Property with Slight Physical Injury." After pleading not guilty trial ensued. RTC of Makati
rendered the decision convicting petitioner of "quasi offense of reckless imprudence, resulting in damage
to property with slight physical injuries" with arresto mayor of 6 months imprisonment and a fine of P
13,542.00. Petitioner made an appeal before the CA which re-affirmed the lower courts decision. In its
motion for reconsideration, petitioner now assails that (1) the court erred in giving its penalty on
complex damage to property and slight physical injuries both being light offenses over which the RTC has
no jurisdiction and it cant impose penalty in excess to what the law authorizes, and (2) reversal of decision
is still possible on ground of prescription or lack of jurisdiction.
Issue:
Whether or not RTC of Makati has jurisdiction over the quasi offenses in question.
Held:
Negative. The jurisdiction to try a criminal action is to be determined by the law in force at the
time of the institution of the action, unless the statute expressly provides, or is construed to the effect
that it is intended to operate as to actions pending before its enactment.
At the time of the filing of the information in this case, the law in force was Batas Pambansa Blg. 129,
otherwise known as The Judiciary Reorganization Act of 1980. Section 32(2) thereof provided that except
in cases falling within the exclusive original jurisdiction of the Regional Trial Courts and of the
Sandiganbayan, the Metropolitan Trial Courts (MeTCs), Municipal Trial Courts (MTCs), and Municipal
Circuit Trial Courts (MCTCs) had exclusive original jurisdiction over all offenses punishable with
imprisonment of not exceeding four years and two months, or a fine of not more than four thousand
pesos, or both fine and imprisonment, regardless of other imposable accessory or other penalties,
including the civil liability arising from such offenses or predicated thereon, irrespective of kind, nature,
value or amount thereof.
Since offenses punishable by imprisonment of not exceeding 4 years and 2 months were within the
jurisdictional ambit of the MeTCs, MTCs and MCTCs, it follows that those penalized with censure, which
is a penalty lower than arresto menor under the graduated scale in Article 71 of the Revised Penal Code
and with a duration of 1 to 30 days, should also fall within the jurisdiction of said courts. Thus, reckless
imprudence resulting in slight physical injuries was cognizable by said courts.
As to the reckless imprudence resulting in damage to property in the amount of P8,542.00, the same
was also under the jurisdiction of MeTCs, MTCs or MCTCs because the imposable penalty therefor
was arresto mayor in its minimum and medium periods -- the duration of which was from 1 month and 1
day to 4 months.
Criminal Case No. 33919 should, therefore, be dismissed for lack of jurisdiction on the part of the RTC
of Makati.

MARY GRACE L. RENON BL 3

Criminal Procedures
BONDOC VS. SANDIGANBAYAN
G.R. No. 71163-65, November 9, 1990

Facts:
Bondoc and Vicente, private individuals, were charged with several felonies of estafa thru
falsification of public documents as principals by indispensable cooperation with employees of
the Central Bank, and other private individuals. However, Bondoc and Vicente were not
investigated and indicted until long after the criminal proceedings against their co-principals had
commenced, and the latter's cases had already been submitted for decision when Bondoc's and
Vicente's own cases came up for trial. Bondoc moved to quash the informations on January 3,
1985 on the basic theory that as a private individual charged as co-principal with government
employees, he should be tried jointly with the latter pursuant to Section 4 (paragraph 3) of PD
1606, as amended, supra; hence, the separate proceedings commenced against him were invalid,
for lack of jurisdiction of the Sandiganbayan over the offenses and his person. The Third Division
of Sandiganbayan denied Bondocs motion to quash, hence this petition for reconsideration.
Issue:
Whether or not the Sandiganbayan lost jurisdiction over Bondoc's cases for its failure to
try jointly his cases with public officers or employees, and whether or not, as a consequence,
those cases became cognizable by the regular courts and should be transferred thereto for trial
and adjudgment.
Held:
No. The seeming impossibility of a joint trial cannot and does not alter the essential nature
of the crimes in question, as felonies perpetrated by public officers or employees in confabulation
with private persons. Assuming it is correct to construe the law in a strictly literal sense, the
indicated course of action would be to insist on holding a joint trial regardless of whatever
circumstances may appear to make such a joint trial inappropriate, inconvenient, unfeasible.
Thus, for instance, the cases in the Second Division, although already submitted for decision,
should be reopened to allow for the consolidation of Bondoc's cases with those of the defendants
therein, and the reception of evidence against and for Bondoc. Indeed, even in the extreme
hypothesis of appeal having already been taken by Bondoc's co-accused, the course of action
dictated by a literal construction of the provision on joint trial is the remand of the appealed case
to the Sandiganbayan so that the joint trial may be conducted. To construe the law in the manner
indicated, however, would be unreasonable, if not absurd, and settled is the rule that courts
should not give a statute a meaning that would lead to absurdities
Furthermore, it is not legally possible to transfer Bondoc's cases to the Regional Trial
Court, for the simple reason that the latter would not have jurisdiction over the offenses. These
crimes are within the exclusive, original jurisdiction of the Sandiganbayan. They simply cannot be
taken cognizance of by the regular courts, apart from the fact that even if the cases could be so
transferred, a joint trial would nonetheless not be possible.

MARY GRACE L. RENON BL 3

Criminal Procedures

PEOPLE VS RAMOS
207 SCRA 144
Facts:
Issue:
Held: