MURAO, JOSE PEPITO III

I. Article III Section 1, Equal Protection:

Lacson v. Executive Secretary G.R. No.128096

Facts:
On May 18, 1995, 11 persons from the Kuratong Baleleng gang, an alleged syndicate involved in a series of bank
robberies in Metro Manila, were killed along Commonwealth Avenue in Quezon City. The Anti-Bank Robbery
Intelligence Task Group (ABRITG) organized by Philippine National Police involving many other subgroups in the
PNP and other lawful divisions was the proponent of such killings, which was reportedly a shoot-out between the
law enforcers and syndicate. However, a member one subgroup exposed to the media that what transpired was a
summary execution, not a shoot-out. An Ombudsman panel were tasked to investigate and later ruled that the
incident was a legitimate police operation. Contrary to this, the Overall Deputy Ombudsman Francisco Villa
recommended the indictment for multiple murders against 26 respondents. Thus, on November 1995, eleven
informations for murder before the Sandiganbayan were filed against herein petitioners, with others being charged
as accessories after-the-fact.
The accused filed separate motions questioning the jurisdiction of the Sandiganbayan and asserting that their case
falls under the jurisdiction of Trial Courts. Primarily, those accused cite R.A. 7975 or an Act to Strengthen the
Functional and Structural Organization of the Sandiganbayan, which state that said appellate court only has
jurisdiction over cases wherein the principal has a Salary Grade of 27 or higher or PNP officials with the rank of
Chief Superintendent or higher. For their case, the highest-ranking principal was only a Chief inspector with none
having a Salary Grade of 27. Therefore, initially, with a vote of 3-2, the Court ruled for the transfer of the cases to
the Quezon City Trial Court.
The Office of the Special Prosecutor moved for reconsideration and while the motion was pending, House bill 2299
and 1094, and Senate Bill 844 were made into law, amending the jurisdiction of the Sandiganbayan by deleting the
words ‘principally’. Hence, Justices ruled 4-1, in favor of the appeal that Sandiganbayan does have jurisdiction of
such cases. The petitioners allege that since a Senator and two Justices of the Sandiganbayan were proponents of the
aforementioned bills, such bill was dedicated to their case specifically. Moreover, the law on widening the
jurisdiction of the Sandiganbayan also closed the two-tiered appeal process they had before.
Issues:
1) W/N Petitioners have been prejudiced as R.A. 8249 circumvented their two-tiered appeal process acquired
in the previous Act?
NO. Right to appeal is not a natural right but statutory in nature and can be regulated by law. R.A. 8249 not
being a penal law may be applied retroactively.
2) W/N Petitioners’ can raise equal protection as the Sandiganbayan have been made to handle their case?
NO. Despite the fact that a Senator and two Sandiganbayan Justices played a part in the passing of the bill
to expand Sandiganbayan’s jurisdiction, the law facilitating such shift applies to all similar cases. Also, 23
other Senators and 250 Representatives as well as the President had a hand in enacting such bills.
Held:
Despite the non-violation of equal protection and procedural rights of herein appellants, the Supreme Court finds
that the amended information against the appellants do not specify how the public officials’ played a part in the
commission of the alleged crime. Thus, as R.A. 8249 has been held to be CONSTITUTIONAL, the Sandiganbayan
is directed to transfer criminal cases to the RTC of Quezon City which has exclusive original jurisdiction over said
cases.