G.R. Nos. 242506-10 and 242590-94. September 14, 2022
LUIS RAMON P. LORENZO and ARTHUR CUA YAP, PETITIONERS, VS. HON. SANDIGANBAYAN (SIXTH DIVISION) AND THE PEOPLE OF THE PHILIPPINES, RESPONDENTS.

FACTS

Petitioners Luis Ramon P. Lorenzo, then Secretary of the Department of Agriculture (DA), and Arthur C. Yap, then Administrator of the National Food Authority (NFA), were charged before the Sandiganbayan with five counts of violating Section 3(e) of R.A. 3019 (Anti-Graft and Corrupt Practices Act). The charges stemmed from the alleged anomalous Luzon-wide procurement of fertilizer for the 2003 Ginintuang Masaganang Ani (GMA) Rice Program. The Ombudsman alleged that Lorenzo and Yap, in conspiracy with a private representative, gave unwarranted benefits to Philippine Phosphate Fertilizer Corporation (Philphos) by directing the use of negotiated procurement instead of public bidding, centralizing the bid opening in Manila, and amending guidelines to allow Manila-based Philphos to participate, thereby causing undue injury to the government.
Petitioners filed Motions to Quash the Informations, arguing primarily that the Sandiganbayan lacked jurisdiction because the Informations failed to allege that the accused public officers had “salary grade 27 or higher,” a jurisdictional requirement under P.D. 1606, as amended. They contended that the allegation of “salary grade 30” was a mere conclusion of law. The Sandiganbayan denied the motions, holding that the allegation of salary grade 30 was a sufficient factual averment of jurisdiction. Petitioners elevated the case via certiorari under Rule 65.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the Motions to Quash based on the alleged failure of the Informations to properly allege facts conferring jurisdiction.

RULING

The Supreme Court dismissed the petitions and affirmed the Sandiganbayan’s Resolutions. The Court held that the Sandiganbayan did not commit grave abuse of discretion. The Informations sufficiently alleged facts vesting jurisdiction by expressly stating that petitioners Lorenzo and Yap were public officers “with salary grade 30,” being the Secretary of Agriculture and NFA Administrator, respectively. Jurisdiction over the offense is determined by the allegations in the Information. The phrase “salary grade 30” is a factual allegation, not a mere conclusion of law. It directly corresponds to the statutory requirement for Sandiganbayan jurisdiction over officials of Salary Grade 27 and higher. The Court emphasized that in a motion to quash, the facts alleged in the Information are deemed hypothetically admitted. The sufficiency of these allegations to vest jurisdiction is a question of law, and the Sandiganbayan’s interpretation was a valid exercise of judicial discretion, not a whimsical or capricious act constituting grave abuse. The Court further noted that any challenge regarding the accuracy of the salary grade classification is a matter of defense best ventilated during trial, not a ground for quashing the Information at the preliminary stage. The denial of the motions was therefore proper.