G.R. Nos. L-50581-50617, January 30, 1982
RUFINO V. NUÑEZ, petitioner, vs. SANDIGANBAYAN and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

The case involves constitutional challenges to Presidential Decree No. 1606, which created the Sandiganbayan. The petitioner, Rufino V. Nuñez, assailed the decree’s validity. The main decision, penned by Chief Justice Fernando, upheld the constitutionality of P.D. 1606. This digest focuses on the separate concurring opinions of Justices Barredo and Makasiar, which provide nuanced views on specific provisions of the law.
Justice Barredo concurred with the main ruling that the Sandiganbayan’s creation and its special procedures were constitutional. He emphasized its sui generis nature as a “special court” mandated under the Constitution’s article on Accountability of Public Officers, not the Judiciary article. However, he strongly objected to provisions placing the Sandiganbayan on a higher administrative plane than the Supreme Court, particularly regarding the automatic release of its appropriations, viewing this as an improper status inversion.

ISSUE

The core constitutional issues dissected in the separate opinions are: (1) Whether the special composition and appellate procedure of the Sandiganbayan under P.D. 1606 violate constitutional prohibitions, and (2) Whether specific provisions of P.D. 1606 improperly exempt the Sandiganbayan from the Supreme Court’s constitutional powers of supervision and rule-making.

RULING

Justice Barredo ruled that the Sandiganbayan’s special structure and the provision for appeals solely on questions of law were constitutional. He reasoned that creating a special court for already-committed crimes is not an ex-post facto law, drawing analogy to historical special courts like the People’s Court. He argued that a conviction based on substantial evidence from a three-judge panel satisfies the reasonable doubt standard, and limiting Supreme Court review to legal questions mirrors its relationship with the Court of Appeals. However, he maintained that any rule-making power granted to the Sandiganbayan must be subject to Supreme Court approval under the Constitution.
Justice Makasiar, in a separate opinion, concurred in the result but found specific provisions unconstitutional. He identified Sections 7, 9, 10, 12, and 13 of P.D. 1606 as violative of the Supreme Court’s constitutional authority. He argued that provisions granting the Sandiganbayan autonomous rule-making power, allowing it to appoint its own personnel, and requiring it to submit its annual report directly to the President unduly infringed upon the Supreme Court’s powers of supervision over all lower courts and its exclusive rule-making authority. He concluded these offending provisions were separable and could be declared invalid without nullifying the entire decree, allowing the Sandiganbayan to function under the Supreme Court’s supervisory umbrella as constitutionally required.