LANDBANK VS BELISTA
G.R. No. 164631
June 26, 2009
FACTS:
Sps. Ralla donated their eight (8) parcels of lot located in Ligao, Albay to
their daughter, Rene Ralla Belista, the herein private respondent. The said parcels
were placed under CARP. Consequently, private respondent claimed payment of
just compensation over said agricultural lands. Believing that her lots were grossly
underestimated by Landbank, private respondent, on 11 November 2002, filed a
Petition for Valuation and Payment of Just Compensation against petitioning bank
before the DARAB-Regional Adjudicator for Region V. Aggrieved by the DARAB's
decision, petitioner Bank, on 28 October 2003, filed an original Petition for
Determination of Just Compensation at RTC. The court a quo motu propio
dismissed the case when it issued an order dated 12 November 2003 for failure to
exhaust administrative remedies and/or comply with Sections 5, 6, and 7, Rule XIX,
2003 DARAB Rules of Procedure, violative of the doctrine of non-exhaustion of
administrative remedies.
ISSUE: Whether or not DARAB and not RTC has the jurisdiction of the
Petition for Determination of Just Compensation of the subject
lot.
RULING:
The RTC has jurisdiction. Under Section 50, DAR has primary jurisdiction
to determine and adjudicate agrarian reform matters and exclusive original
jurisdiction over all matters involving the implementation of agrarian reform, except
those falling under the exclusive jurisdiction of the DA and the DENR. Further
exception to the DAR's original and exclusive jurisdiction are all petitions for the
determination of just compensation to landowners and the prosecution of all criminal
offenses under RA No. 6657, which are within the jurisdiction of the RTC sitting as a
Special Agrarian Court. Thus, jurisdiction on just compensation cases for the taking
of lands under RA No. 6657 is vested in the courts. In Republic v. CA, the Court
explained: Thus, Special Agrarian Courts, which are Regional Trial Courts, are
given original and exclusive jurisdiction over two categories of cases, to wit: (1) all
petitions for the determination of just compensation to landowners and (2) the
prosecution of all criminal offenses under [R.A. No. 6657].
Although Section 5, Rule XIX of the 2003 DARAB Rules of Procedure provides that
the land valuation cases decided by the adjudicator are now appealable to the
Board, such rule could not change the clear import of Section 57 of RA No. 6657
that the original and exclusive jurisdiction to determine just compensation is in the
RTC. Thus, Section 57 authorizes direct resort to the SAC in cases involving
petitions for the determination of just compensation.[14] In accordance with the said
Section 57, petitioner properly filed the petition before the RTC and, hence, the RTC
erred in dismissing the case.
G.R. No. 167304 August 25, 2009
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. SANDIGANBAYAN (THIRD
DIVISION) AND VICTORIA AMANTE, RESPONDENTS.
[PERALTA]
Facts:
Victoria Amante was a member of the Sangguniang Panlungsod of Toledo
City, Province of Cebu at the time pertinent to this case. On January 14, 1994, she
was able to get hold of a cash advance in the amount of P71,095.00 in order to
defray seminar expenses of the Committee on Health and Environmental Protection,
which she headed. No liquidation was made after almost two years and so on
December 22, 1995, a demand letter was issued by the City Auditor asking
respondent to settle her unliquidated cash advance within 72 hours from receipt of
the demand. Upon the recommendation of the Commission on Audit (COA), the
Office of the Deputy Ombudsman for Visayas (OMB-Visayas) resolved to file an
Information for Malversation of Public Funds. The Office of the Special Prosecutor
(OSP) found probable cause to indict respondent Amante and thus on May 21,
2004, the Office of the Special Prosecutor(OSP) filed an Information with the
Sandiganbayan accusing Victoria Amante of violating Section 89 of P.D. No. 1445
(The Auditing Code of the Philippines).
Respondent Amante in her MOTION TO DEFER ARRAIGNMENT AND
MOTION FOR REINVESTIGATION dated November 18, 2004 stated that the
Sandiganbayan had no jurisdiction over the said criminal case because respondent
Amante was then a local official who was occupying a position of salary grade 26,
whereas Section 4 of Republic Act (R.A.) No. 8249 provides that the
Sandiganbayan shall have original jurisdiction only in cases where the accused
holds a position otherwise classified as Grade 27 and higher, of the Compensation
and Position Classification Act of 1989, R.A. No. 6758.
 The Sandiganbayan, in its Resolution dated February 28, 2005, dismissed
the case against Amante for lack of jurisdiction. The dismissal, however, is without
prejudice to the filing of this case to the proper court.
Issue/s:
Whether or not a member of the Sangguniang Panlungsod under Salary
Grade 26 who was charged with violation of The Auditing Code of the Philippines
falls within the jurisdiction of the Sandiganbayan.
Ruling:
The present case falls under P.D. No. 1606 as amended by R.A. No.
8249. Under Section 4(a) of said law, the following offenses are specifically
enumerated: violations of R.A. No. 3019, as amended, R.A. No. 1379, and Chapter
II, Section 2, Title VII of the Revised Penal Code. In order for the Sandiganbayan to
acquire jurisdiction over the said offenses, the latter must be committed by, among
others, officials of the executive branch occupying positions of regional director and
higher, otherwise classified as Grade 27 and higher, of the Compensation and
Position Classification Act of 1989. However, the law is not devoid of exceptions.
Those that are classified as Grade 26 and below may still fall within the jurisdiction
of the Sandiganbayan provided that they hold the positions thus enumerated by the
same law. Particularly and exclusively enumerated are provincial governors, vice-
governors, members of the Sangguniang Panlalawigan, and provincial treasurers,
assessors, engineers, and other provincial department heads; city mayors, vice-
mayors, members of the Sangguniang Panlungsod, city treasurers, assessors,
engineers , and other city department heads; officials of the diplomatic service
occupying the position as consul and higher; Philippine army and air force colonels,
naval captains, and all officers of higher rank; PNP chief superintendent and PNP
officers of higher rank; City and provincial prosecutors and their assistants, and
officials and prosecutors in the Office of the Ombudsman and special prosecutor;
and presidents, directors or trustees, or managers of government-owned or
controlled corporations, state universities or educational institutions or foundations.
In connection therewith, Section 4(b) of the same law provides that other offenses or
felonies committed by public officials and employees mentioned in subsection (a) in
relation to their office also fall under the jurisdiction of the Sandiganbayan.
By simple analogy, applying the provisions of the pertinent law,
respondent Amante, being a member of the Sangguniang Panlungsod at the time of
the alleged commission of an offense in relation to her office, falls within the original
jurisdiction of the Sandiganbayan. The provision of the law shows that those public
officials enumerated in Section 4(a) of P.D. No. 1606, as amended, may not only be
charged in the Sandiganbayan with violations of R.A. No. 3019, R.A. No. 1379 or
Chapter II, Section 2, Title VII of the Revised Penal Code, but also with other
offenses or felonies in relation to their office. The said other offenses and felonies
are broad in scope but are limited only to those that are committed in relation to the
public official or employee's office.
In the offenses involved in Section 4(a), public office is essential as an
element of the said offenses themselves, while in those offenses and felonies
involved in Section 4(b), it is enough that the said offenses and felonies were
committed in relation to the public officials or employees' office. Moreover, Section
4(b) does not mention any qualification as to the public officials involved. It simply
stated, public officials and employees mentioned in subsection (a) of the same
section. Therefore, it refers to those public officials with Salary Grade 27 and above,
except those specifically enumerated. It is a well-settled principle of legal
hermeneutics that words of a statute will be interpreted in their natural, plain and
ordinary acceptation and signification, unless it is evident that the legislature
intended a technical or special legal meaning to those words.
The Petition was GRANTED and the Resolution of the Sandiganbayan
(Third Division) NULLIFIED and SET ASIDE. Consequently, case was REMANDED
to the Sandiganbayan for further proceedings.
G.R. No. 162059 January 22, 2008
HANNAH EUNICE D. SERANA vs. SANDIGANBAYAN and PEOPLE OF THE
PHILIPPINES
FACTS: Petitioner Hannah Eunice D. Serana was a senior student of the UP-Cebu.
She was appointed by then President Joseph Estrada on December 21, 1999 as a
student regent of UP, to serve a one-year term starting January 1, 2000 and ending
on December 31, 2000. On September 4, 2000, petitioner, with her siblings and
relatives, registered with the SEC the Office of the Student Regent Foundation, Inc.
(OSRFI).3 One of the projects of the OSRFI was the renovation of the Vinzons Hall
Annex.4 President Estrada gave P15,000,000.00 to the OSRFI as financial
assistance for the proposed renovation. The source of the funds, according to the
information, was the Office of the President. The renovation of Vinzons Hall Annex
failed to materialize.5 The succeeding student regent, Kristine Clare Bugayong, and
Christine Jill De Guzman, Secretary General of the KASAMA sa U.P., a system-
wide alliance of student councils within the state university, consequently filed a
complaint for Malversation of Public Funds and Property with the Office of the
Ombudsman.6 The Ombudsman found probable cause to indict petitioner and her
brother Jade Ian D. Serana for estafa and filed the case to the
Sandiganbayan.7 Petitioner moved to quash the information. She claimed that the
Sandiganbayan does not have any jurisdiction over the offense charged or over her
person, in her capacity as UP student regent. The Sandiganbayan denied
petitioner’s motion for lack of merit. Petitioner filed a motion for reconsideration but
was denied with finality.
ISSUE: (1) Whether or not the Sandiganbayan has jurisdiction over an estafa case?
(2) Whether or not petitioner is a public officer with Salary Grade 27?
DOCTRINE: (1) Section 4(B) of P.D. No. 1606 which defines the jurisdiction of the
Sandiganbayan reads: “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.” (2) While the first part of
Section 4(A) covers only officials with Salary Grade 27 and higher, its second part
specifically includes other executive officials whose positions may not be of Salary
Grade 27 and higher but who are by express provision of law placed under the
jurisdiction of the said court.
RATIONALE:
(1) The rule is well-established in this jurisdiction that statutes should receive a
sensible construction so as to avoid an unjust or an absurd conclusion. 33 Every
section, provision or clause of the statute must be expounded by reference to each
other in order to arrive at the effect contemplated by the legislature. 34 Evidently,
from the provisions of Section 4(B) of P.D. No. 1606, the Sandiganbayan has
jurisdiction over other felonies committed by public officials in relation to their office.
Plainly, estafa is one of those other felonies. The jurisdiction is simply subject to the
twin requirements that (a) the offense is committed by public officials and
employees mentioned in Section 4(A) of P.D. No. 1606, as amended, and that (b)
the offense is committed in relation to their office.
(2) Petitioner falls under the jurisdiction of the Sandiganbayan, even if she does not
have a salary grade 27, as she is placed there by express provision of law. 44
Section 4(A)(1)(g) of P.D. No. 1606 explictly vested the Sandiganbayan with
jurisdiction over Presidents, directors or trustees, or managers of government-
owned or controlled corporations, state universities or educational institutions or
foundations. Petitioner falls under this category. As the Sandiganbayan pointed out,
the BOR performs functions similar to those of a board of trustees of a non-stock
corporation.45 By express mandate of law, petitioner is, indeed, a public officer as
contemplated by P.D. No. 1606.
G.R. No. 137237
September 17, 2002
Petitioners: Antonio Esquivel and Mark Anthony Esquivel
Respondents: Ombudsman, Sandiganbayan, People of the Philippines,
Herminigildo Eduardo
ESQUIVEL v. OMBUDSMAN
Facts:
Police officers Eduardo and Catacutan charged herein petitioners Antonio
Prospero Esquivel, municipal mayor of Jaen and his brother, Mark Anthony "Eboy"
Esquivel, barangay captain of barangay Apo, Jaen, with alleged illegal arrest,
arbitrary detention, maltreatment, attempted murder, and grave threats. According
to Eduardo, he was about to eat lunch at his parents’ house at Nueva Ecija, when
petitioners arrived who disarmed him of his Cal. 45 service pistol. They then forced
him to board petitioners’ vehicle and brought him to the Jaen Municipal Hall. On the
way to the town hall, Mayor Esquivel mauled him with the use of a firearm and
threatened to kill him. Mayor Esquivel pointed a gun at PO2 Eduardo and said,
"Putang-ina mo, papatayin kita, aaksidentihin kita dito, bakit mo ako kinakalaban!"
Mayor Esquivel then ordered SPO1 Espiritu to kill him, saying "Patayin mo na iyan
at gawan ng senaryo at report." He was struck with a handgun and released. Prior
to his release, however, he was forced to sign a statement in the police blotter that
he was in good physical condition.
PO2 Eduardo told the PNP-CIDG investigators that he was most likely
maltreated and threatened because of jueteng and tupada. He said the mayor
believed he was among the law enforcers who raided a jueteng den in Jaen that
same day. He surmised that the mayor disliked the fact that he arrested members
of crime syndicates with connections to the mayor.
Thereafter, separate informations docketed as Criminal Case No. 24777
for less serious physical injuries against Mayor Esquivel and Mark Anthony "Eboy"
Esquivel, and Criminal Case No. 24778 for grave threats against petitioner mayor,
were filed with the Sandiganbayan. Petitioners submit that Sandiganbayan has no
jurisdiction over the offenses filed against petitioners, and thus committed GAD
when it assumed jurisdiction.
Issue: WON Sandiganbayan has Jurisdiction? YES

Held:
Petitioners theorize that the Sandiganbayan has no jurisdiction over their
persons as they hold positions excluded in Republic Act No. 7975. As the positions
of municipal mayors and barangay captains are not mentioned therein, they claim
they are not covered by said law under the principle of expressio unius est exclusio
alterius.
Petitioners’ claim lacks merit. In Rodrigo, Jr. vs. Sandiganbayan, Binay vs.
Sandiganbayan, and Layus vs. Sandiganbayan, we already held that municipal
mayors fall under the original and exclusive jurisdiction of the Sandiganbayan. Nor
can Barangay Captain Mark Anthony Esquivel claim that since he is not a municipal
mayor, he is outside the Sandiganbayan’s jurisdiction. R.A. 7975, as amended by
R.A. No. 8249, provides that it is only in cases where "none of the accused
(underscoring supplied) are occupying positions corresponding to salary grade ‘27’
or higher"36 that "exclusive original jurisdiction shall be vested in the proper regional
trial court, metropolitan trial court, municipal trial court, and municipal circuit court,
as the case may be, pursuant to their respective jurisdictions as provided in Batas
Pambansa Blg. 129, as amended."37 Note that under the 1991 Local Government
Code, Mayor Esquivel has a salary grade of 27. Since Barangay Captain Esquivel is
the co-accused in Criminal Case No. 24777 of Mayor Esquivel, whose position falls
under salary grade 27, the Sandiganbayan committed no grave abuse of discretion
in assuming jurisdiction over said criminal case, as well as over Criminal Case No.
24778, involving both of them. Hence, the writ of certiorari cannot issue in
petitioners’ favor.
Esteban v Sandiganbayan
G.R. NO. 146646069, March 11, 2005
Facts:
 Ana May alleged that she was a casual employee of the City Government
of Cabanatuan City. Sometime in February 1997, she was detailed with
the Municipal Trial Court in Cities (MTCC), Branch 1, Cabanatuan City,
upon incessant request of Presiding Judge Reogelio Esteban, herein
petitioner.
 Ana May alleged that she was a casual employee of the City Government
of Cabanatuan City. Sometime in February 1997, she was detailed with
the Municipal Trial Court in Cities (MTCC), Branch 1, Cabanatuan City,
upon incessant request of Presiding Judge Reogelio Esteban, herein
petitioner.
 On July 25, 1997, when she approached petitioner in his chambers to
follow up her application, he told her, Ano naman ang magiging kapalit ng
pagpirma ko rito? Mula ngayon, girlfriend na kita. Araw-araw papasok ka
dito sa opisina ko, at araw-araw, isang halik. (What can you offer me in
exchange for my signature? From now on, you are my girlfriend. You will
enter this office everyday and everyday, I get one kiss.
 Ana May refused to accede to his proposal as she considered him like her
own father.
 Petitioner nonetheless recommended her for appointment. Thereafter, he
suddenly kissed her on her left cheek. She was shocked and left the
chambers, swearing never to return or talk to petitioner.
 Petitioner nonetheless recommended her for appointment. Thereafter, he
suddenly kissed her on her left cheek. She was shocked and left the
chambers, swearing never to return or talk to petitioner.
 Petitioner nonetheless recommended her for appointment. Thereafter, he
suddenly kissed her on her left cheek. She was shocked and left the
chambers, swearing never to return or talk to petitioner.
Issue: whether the Sandiganbayan has jurisdiction over Criminal Cases Nos. 24703-
04 for acts of lasciviousness filed against petitioner.
 Petitioner contends that the alleged acts of lasciviousness were not
committed in relation to his office as a judge; and the fact that he is a
public official is not an essential element of the crimes charged.
Ruling:
 The petition is bereft of merit.
 Section 4 of Presidential Decree No. 1606, as amended by Republic Act
No. 8249,[10] reads in part:
 SEC. 4. Jurisdiction. The Sandiganbayan shall exercise exclusive original
jurisdiction in all cases involving:
 xxx
 b. Other offenses or felonies whether simple or complexed with other
crime committed by the public officials and employees mentioned in
subsection a of this section in relation to their office.
 Under Supreme Court Circular No. 7 dated April 27, 1987,[15] petitioner, as
 presiding judge of MTCC, Branch 1, Cabanatuan City, is vested with the
power to recommend the appointment of Ana May Simbajon as
bookbinder. As alleged in the Amended Informations in Criminal Cases
Nos. 24703-04, she was constrained to approach petitioner on June 25,
1997 as she needed his recommendation. But he imposed a condition
before extending such recommendation - she should be his girlfriend and
must report daily to his office for a kiss.
 There can be no doubt, therefore, that petitioner used his official position
in committing the acts complained of. While it is true, as petitioner argues,
that public office is not an element of the crime of acts of lasciviousness,
defined and penalized under Article 336 of the Revised Penal Code,
nonetheless, he could not have committed the crimes charged were it not
for the fact that as the Presiding Judge of the MTCC, Branch I,
Cabanatuan City, he has the authority to recommend the appointment of
Ana May as bookbinder. In other words, the crimes allegedly committed
are intimately connected with his office.
 The jurisdiction of a court is determined by the allegations in the complaint
or information.[16] The Amended Informations in Criminal Cases Nos.
24703-04 contain allegations showing that the acts of lasciviousness were
committed by petitioner in relation to his official function.
AMBIL VS. SANDIGANBAYAN
FACTS: Eastern Samar Governor Ruperto Ambil and Provincial warden
Alexandrino Apelado were found guilty before the Sandiganbayan for violating
Section 3(e) of Republic Act No. 3019 otherwise known as the Anti-Graft and
Corrupt Practices Act after Governor Ambil, conspiring with Apelado, ordered the
release of then criminally-charged and detained mayor Francisco Adalim and had
the latter transferred from the provincial jail to the the governor’s residence. They
allowed said Mayor Adalim to stay at accused Ambils residence for a period of
Eighty-Five (85) days, more or less which act was done without any court
order
Petitioners admitted the allegations in the Information. They reason,
however, that Adalims transfer was justified considering the imminent threats
upon his person and the dangers posed by his detention at the provincial jail.
Sandiganbayan, First Division, promulgated the assailed Decision
finding petitioners guilty of violating Section 3(e) of R.A. No. 3019.
*Defense:
Ambil, Jr. argues that Section 3(e), R.A. No. 3019 does not apply to
his case because the provision contemplates only transactions of a pecuniary
nature. Since the law punishes a public officer who extends unwarranted
benefits to a private person, petitioner avers that he cannot be held liable for
extending a favor to Mayor Adalim, a public officer.
Further, he claims good faith in taking custody of the mayor pursuant
to his duty as a Provincial Jailer under the Administrative Code of 1917.
Considering this, petitioner believes himself entitled to the justifying
circumstance of fulfillment of duty or lawful exercise of duty.
Petitioner Apelado, Sr., on the other hand, denies allegations of
conspiracy between him and petitioner Ambil, Jr. Petitioner Apelado, Sr.
defends that he was merely following the orders of a superior when he
transferred the detention of Adalim. As well, he invokes immunity from
criminal liability.
*Prosecution:
Office of the Special Prosecutor (OSP) points out the absence of
jurisprudence that restricts the application of Section 3(e), R.A. No. 3019 to
transactions of a pecuniary nature. The OSP explains that it is enough to show
that in performing their functions, petitioners have accorded undue preference to
Adalim for liability to attach under the provision.
OSP also reiterates petitioners lack of authority to take custody of a
detention prisoner without a court order. Hence, it concludes that petitioners
are not entitled to the benefit of any justifying circumstance.
Issue: Are the accused liable?
Held: No because the third element is lacking.
In order to hold a person liable under this provision, the following elements
must concur: (1) the accused must be a public officer discharging
administrative, judicial or official functions; (2) he must have acted with
manifest partiality, evident bad faith or gross inexcusable negligence; and (3)
his action caused any undue injury to any party, including the government, or
gave any private party unwarranted benefits, advantage or preference in the
discharge of his functions.

As to the first element, there is no question that petitioners are public

officers. The acused shall be in the jurisdiction of Sandigan bayan because
Governor’s salary grade is more than 27 and Apelado is a co-accused even though
he has only a salary grade of 22.

As to the second element, SC find that petitioners displayed manifest

partiality and evident bad faith in transferring the detention of Mayor Adalim to
petitioner Ambil, Jr.s house. There is no merit to petitioner Ambil, Jr.s contention
that he is authorized to transfer the detention of prisoners by virtue of his power as
the Provincial Jailer of Eastern Samar.

As to there third element it is also present. In the case at hand, the

Information specifically accused petitioners of giving unwarranted benefits and
advantage to Mayor Adalim, a public officer charged with murder, by causing his
release from prison and detaining him instead at the house of petitioner Ambil, Jr.
Petitioner Ambil, Jr. negates the applicability of Section 3(e), R.A. No. 3019 in this
case on two points. First, Section 3(e) is not applicable to him allegedly because
the last sentence thereof provides that the provision shall apply to officers and
employees of offices or government corporations charged with the grant of licenses,
permits or other concessions and he is not such government officer or employee.
Second, the purported unwarranted benefit was accorded not to a private party but
to a public officer.