G.R. No. 120681-83 and G.R. No. 128136, October 1, 1999.
Case Parties:

G.R. Nos. 120681-83: JEJOMAR C. BINAY, petitioner, vs. HON. SANDIGANBAYAN (Third Division) and the DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT, respondents.
G.R. No. 128136: MARIO C. MAGSAYSAY, FRANCISCO B. CASTILLO, CRISTINA D. MABIOG, REGINO E. MALAPIT, ERLINDA I. MASANGCAY and VICENTE DE LA ROSA, petitioners, vs. HON. SANDIGANBAYAN, HON. OMBUDSMAN and its PROSECUTOR WENDELL BARERRAS-SULIT and STATE PROSECUTORS ERIC HENRY JOSEPH F. MALLONGA and GIDEON C. MENDOZA, respondents.

FACTS

In G.R. Nos. 120681-83, petitioner Jejomar Binay, then Mayor of Makati, was charged before the Sandiganbayan in September 1994 with one violation of Article 220 of the Revised Penal Code and two violations of Section 3(e) of R.A. No. 3019 for acts allegedly committed in 1987. After his motions to quash were denied and an order for his suspension pendente lite was issued, Republic Act No. 7975, redefining the Sandiganbayan’s jurisdiction, took effect on May 16, 1995. Binay filed a motion to refer his cases to the proper court, arguing the Sandiganbayan had lost jurisdiction. The Sandiganbayan denied the motion, ruling that Municipal Mayors are classified as Grade “27” under the Compensation & Position Classification Act of 1989 (R.A. No. 6758), and thus it retained jurisdiction under Section 4(e)5 of the law. Binay filed a petition for certiorari, prohibition, and mandamus challenging this jurisdiction.
In G.R. No. 128136, petitioner Mario Magsaysay, Mayor of San Pascual, Batangas, and other municipal officials were charged before the Office of the Ombudsman with violation of R.A. No. 3019. The Ombudsman recommended filing an information with the Sandiganbayan. The Sandiganbayan initially suspended proceedings pending this Court’s ruling in the Binay cases but later reversed itself and asserted jurisdiction. The petitioners assailed this resolution.
The central issue in these consolidated petitions is whether the Sandiganbayan, under R.A. Nos. 7975 and 8249, exercises exclusive original jurisdiction over criminal cases involving municipal mayors accused of violations of R.A. No. 3019 and the Revised Penal Code.

ISSUE

Whether the Sandiganbayan has jurisdiction over the criminal cases against the petitioners, who are municipal mayors and officials, for violations of R.A. No. 3019 and the Revised Penal Code, in light of the provisions of R.A. No. 7975 and R.A. No. 8249.

RULING

The Supreme Court ruled that the Sandiganbayan has jurisdiction over the cases. The Court held that the jurisdiction of the Sandiganbayan is determined by the applicable law at the time of the institution of the action. R.A. No. 7975, which took effect during the pendency of the cases, governs. Section 2 of R.A. No. 7975 provides that the Sandiganbayan shall exercise exclusive original jurisdiction over violations of R.A. No. 3019 committed by public officials and employees “holding official positions classified as Grade 27 and higher, of the Compensation and Position Classification Act of 1989.” The Court found that the position of Municipal Mayor is classified as Salary Grade 27 under R.A. No. 6758 (the Compensation and Position Classification Act of 1989) and its implementing guidelines. Therefore, municipal mayors fall within the exclusive original jurisdiction of the Sandiganbayan for offenses under R.A. No. 3019. The same principle applies to other offenses committed by officials of equivalent rank in relation to their office. The Court rejected the argument that salary grade should be determined based on the official’s actual salary at the time of the offense’s commission, ruling instead that the classification is determined by the official’s position title as defined by law. Consequently, the petitions were dismissed, and the challenged resolutions of the Sandiganbayan were upheld.