G.R. No. 128096 January 20, 1999
PANFILO M. LACSON, petitioner, vs. THE EXECUTIVE SECRETARY, THE SANDIGANBAYAN, OFFICE OF THE SPECIAL PROSECUTOR, THE DEPARTMENT OF JUSTICE, MYRNA ABALORA, NENITA ALAP-AP, IMELDA PANCHO MONTERO, and THE PEOPLE OF THE PHILIPPINES, respondents. ROMEO M. ACOP AND FRANCISCO G. ZUBIA, JR., petitioner-intervenors.

FACTS

Petitioner Panfilo M. Lacson and intervenors Romeo M. Acop and Francisco G. Zubia, Jr., along with other police officers, were charged before the Sandiganbayan with multiple murder in connection with the May 18, 1995 Kuratong Baleleng incident. Initially charged as a principal, Lacson was later charged as an accessory in amended informations filed on March 1, 1996. The accused moved to question the Sandiganbayan’s jurisdiction, arguing that under Republic Act No. 7975 , the Sandiganbayan’s jurisdiction was limited to cases where one or more of the “principal accused” are officials with Salary Grade 27 or higher or PNP officials with the rank of Chief Superintendent or higher. Since the highest-ranking principal accused in the amended informations was only a Chief Inspector, the cases fell under the jurisdiction of the Regional Trial Court. On May 8, 1996, the Sandiganbayan agreed and ordered the cases transferred to the Quezon City Regional Trial Court. While the prosecution’s motion for reconsideration of this order was pending, Congress passed Republic Act No. 8249 , which deleted the word “principal” from the jurisdictional phrase. Approved on February 5, 1997, the new law contained a provision (Section 7) stating it shall apply to all pending cases where trial had not begun. On March 5, 1997, the Sandiganbayan, citing the new law, issued an Addendum to its resolution, granted the prosecution’s motion for reconsideration, and retained jurisdiction over the cases because three of the accused (Canson, Acop, and Lacson) were PNP Chief Superintendents. Petitioner and intervenors challenge the constitutionality of Sections 4 and 7 of R.A. No. 8249 .

ISSUE

The primary issue is whether Sections 4 and 7 of Republic Act No. 8249 are unconstitutional for allegedly violating: (1) the right to procedural due process and the equal protection clause; (2) the prohibition against ex post facto laws; and (3) the constitutional requirement that every bill shall embrace only one subject expressed in its title.

RULING

The Supreme Court dismissed the petition and upheld the constitutionality of the challenged provisions of R.A. No. 8249 .
1. On Due Process and Equal Protection: The Court ruled that the law was not enacted in bad faith. The deletion of the word “principal” was a curative measure to correct the restrictive interpretation of the Sandiganbayan’s jurisdiction under R.A. No. 7975 , which had caused procedural complications and delays. The law applies to a class (all cases pending where trial has not begun) and not specifically to the petitioners. The alleged delay in the Sandiganbayan’s resolution was not proven to be orchestrated to coincide with the law’s passage.
2. On Ex Post Facto Law: The Court held that R.A. No. 8249 is not an ex post facto law. An ex post facto law refers to criminal, not procedural, laws. R.A. No. 8249 is a procedural statute dealing with jurisdiction, which can be applied retroactively to pending cases. Jurisdiction is conferred by law and can be removed or transferred by Congress at any time, provided it does not impair vested rights. The petitioners had no vested right to be tried by a specific court. The provision in Section 7 applying the law to cases where trial has not begun is a valid specification of its retroactive application, ensuring an orderly administration of justice and avoiding a vacuum in pending cases.
3. On the One Title-One Subject Rule: The Court found that the title of R.A. No. 8249 , “An Act Further Defining the Jurisdiction of the Sandiganbayan,” is comprehensive enough to include the provisions of Sections 4 and 7. Section 4, which deletes the word “principal,” is germane to the purpose of redefining jurisdiction. Section 7, which provides for the law’s applicability, is a standard provision necessary for the orderly implementation of the jurisdictional changes. The title need not be an index of every detail of the law.