GR 161784 86; (April, 2005) (Digest)
G.R. No. 161784 -86. April 26, 2005
DINAH C. BARRIGA, Petitioner, vs. THE HONORABLE SANDIGANBAYAN (4TH DIVISION) and THE PEOPLE OF THE PHILIPPINES, Respondents.
FACTS
Petitioner Dinah C. Barriga, the Municipal Accountant of Carmen, Cebu, was charged before the Sandiganbayan with one count of Malversation of Public Funds and two counts of Illegal Use of Public Funds. The charges stemmed from allegations that she, together with the Municipal Mayor, misappropriated and illegally disbursed specific public funds intended for water system projects. The Sandiganbayan admitted the Amended Informations.
Barriga filed a Motion to Quash, arguing the Sandiganbayan lacked jurisdiction over her person and the offenses. She contended that as a Municipal Accountant classified under Salary Grade 24, she fell below the Salary Grade 27 threshold required for the Sandiganbayan’s jurisdiction over offenses not intrinsically connected to public office under Section 4 of P.D. No. 1606, as amended by R.A. No. 8249 . She further argued that the crimes of Malversation and Illegal Use of Public Funds are not included in the specific crimes listed in the law over which the Sandiganbayan has jurisdiction regardless of salary grade.
ISSUE
Whether or not the Sandiganbayan has jurisdiction over the crimes of Malversation and Illegal Use of Public Funds charged against petitioner, a Municipal Accountant with Salary Grade 24.
RULING
Yes, the Sandiganbayan has jurisdiction. The Supreme Court denied the petition and upheld the Sandiganbayan’s jurisdiction. The legal logic rests on the interpretation of Section 4 of P.D. No. 1606, as amended. The law grants the Sandiganbayan jurisdiction over two main categories of offenses committed by public officials. The first category includes specific offenses like violations of the Anti-Graft and Corrupt Practices Act, regardless of the accused’s salary grade. The second category encompasses “[o]ther offenses or felonies whether simple or complexed with other crimes committed by the public officials and employees… in relation to their office.”
The Court ruled that the charges against Barriga for Malversation and Illegal Use of Public Funds fall squarely under the second category—”other offenses… committed… in relation to their office.” The Informations explicitly allege that she committed the acts “in relation to office” and by reason of her official duties as Municipal Accountant, an accountable officer. Since the crimes were allegedly committed in relation to her office, the Sandiganbayan properly exercises jurisdiction. The determination of whether the crimes were indeed committed in relation to office is a matter of evidence to be presented during trial, not a ground for a motion to quash based on jurisdiction. Therefore, her Salary Grade 24 classification is immaterial for jurisdictional purposes in this instance.