G.R. No. L-65097, February 20, 1984
Gavino Manikad, Roberto Bañez and Benito Arellano, Petitioners, vs. Tanodbayan, Hon. Benjamin T. Vianzon, as Deputized Tanodbayan Prosecutor, Guillermo M. Santos, Jr., and Bernardo S. Yambao, Respondents.

FACTS

Petitioners Gavino Manikad, Roberto Bañez, and Benito Arellano, the director and members of the Export Processing Zone Authority (EPZA) Police Force, were charged before the Tanodbayan by their fellow EPZA police members, respondents Guillermo M. Santos, Jr. and Bernardo S. Yambao. The complaint alleged crimes including smuggling, qualified theft, and violations of the Anti-Graft and Anti-Fencing laws, all purportedly committed within the EPZA zone. The deputized Tanodbayan prosecutor, respondent Benjamin T. Vianzon, assumed jurisdiction and scheduled a preliminary investigation.
Petitioners moved to dismiss the complaint, arguing primarily that the Tanodbayan prosecutor lacked authority to conduct the preliminary investigation. They contended that under Section 7 of Presidential Decree No. 1716-A, the EPZA possessed the exclusive power to receive, investigate, and prosecute complaints concerning penal law violations within the zones it administers. Respondent Fiscal Vianzon denied the motion to dismiss, and the Tanodbayan subsequently denied petitioners’ motion for reconsideration. Petitioners thus filed this petition for certiorari and prohibition, asserting grave abuse of discretion.

ISSUE

Whether the power granted to the EPZA under Section 7 of P.D. No. 1716-A to investigate penal law violations within its zones is exclusive, thereby depriving the Tanodbayan or its deputies of jurisdiction to conduct a preliminary investigation over the complaint against the petitioners.

RULING

The Supreme Court denied the petition, ruling that the Tanodbayan retained concurrent jurisdiction. The legal logic centers on statutory construction of P.D. No. 1716-A. Section 7 provides that the EPZA, “in the exercise of its sole police authority,” shall have the power to receive and investigate complaints and to prosecute cases. The Court emphasized that the term “sole” modifies only “police authority,” referring to ordinary police functions like maintaining peace and order. The subsequent grant of investigative and prosecutorial powers contains no exclusive language such as “sole,” “exclusive,” or similar restrictive terms.
The Court applied the basic rule that a meaning not reflected in the statute’s language cannot be read into it. Since exclusivity was not expressly stated for the investigative function, the power is not exclusive to the EPZA. Consequently, the authority of the Tanodbayan under its charter, P.D. No. 1606, to investigate offenses falling within Sandiganbayan jurisdiction—which include the Anti-Graft violations charged here—remains intact and concurrent. The EPZA’s power is an additional capability, not a limitation on the Tanodbayan’s constitutional and statutory mandate. The Court also found no merit in the claim of premature filing, stating that an administrative proceeding does not bar a criminal prosecution, as they are separate proceedings.