GR 136806; (August, 2000) (Digest)
G.R. No. 136806 ; August 22, 2000
EDUARDO A. ALARILLA, petitioner, vs. THE HONORABLE SANDIGANBAYAN (First Division), respondent.
FACTS
Petitioner Eduardo A. Alarilla, then Municipal Mayor of Meycauayan, Bulacan, was charged before the Sandiganbayan with Grave Threats under the Revised Penal Code. The original information was amended to allege that the crime was committed “in relation to” his office. The amended information stated that during a public hearing concerning factory pollution, after the complainant delivered a privilege speech critical of Alarilla’s administration, the mayor aimed a pistol at and threatened to kill the complainant. Alarilla filed a demurrer to evidence, arguing the Sandiganbayan lacked jurisdiction because the act was not office-related. He cited the dismissal of a related Anti-Graft case (Criminal Case No. 23070) by the Sandiganbayan’s Second Division, which ruled that incident occurred after the hearing and was not done in the discharge of official functions. The Sandiganbayan’s First Division denied the demurrer, prompting this petition for certiorari.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the demurrer to evidence and in ruling that it has jurisdiction over the crime of Grave Threats as alleged in the amended information.
RULING
The Supreme Court dismissed the petition, upholding the Sandiganbayan’s jurisdiction. The Court clarified that jurisdiction is determined by the allegations in the information. The amended information sufficiently alleged that the crime was committed “in relation to” petitioner’s official functions. The incident occurred during a public hearing on a community health issue, which the mayor attended in his official capacity. Furthermore, the violent act was directly precipitated by a criticism of his official administration. The Court distinguished this case from the dismissed Anti-Graft case. For violation of R.A. 3019, it is an essential element that the act be done “in the discharge of official functions.” For jurisdiction over other crimes under P.D. 1606, as amended, the requirement is that the offense be committed “in relation to office,” which is a broader standard requiring only an intimate connection between the crime and official duties. The allegations here met this broader standard, as the act was intimately connected to his performance of duty and his response to an attack on his office. Therefore, the Sandiganbayan correctly assumed jurisdiction and did not commit grave abuse of discretion.