GR 188630; (February, 2011) (Digest)
G.R. No. 188630; February 23, 2011
FILOMENA L. VILLANUEVA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Filomena L. Villanueva was the Assistant Regional Director of the Cooperative Development Authority (CDA) of Region II, a position lower than Salary Grade 27. She and her husband obtained loans from the Cagayan Agri-Based Multi-Purpose Cooperative, Inc. (CABMPCI). Her husband defaulted, leading CABMPCI to file a civil collection case. During the pendency of the civil case, an administrative complaint for Willful Failure to Pay Just Debt was filed against petitioner before the CDA. The civil case resulted in a default judgment against her husband, which was later nullified by the Court of Appeals on the ground of payment. Subsequently, an administrative case was filed with the Office of the Ombudsman, which found petitioner guilty of Grave Misconduct. This Ombudsman decision was later reversed by the Court of Appeals.
Separately, a criminal case for violation of Section 2(d) of R.A. No. 6713 (Code of Conduct and Ethical Standards) was filed against petitioner before the Municipal Circuit Trial Court (MCTC). The MCTC convicted her. She appealed to the Regional Trial Court (RTC), which affirmed the conviction. Petitioner then filed a petition for review before the Court of Appeals (CA). The Office of the Solicitor General moved to dismiss, arguing the Sandiganbayan had exclusive appellate jurisdiction. The CA dismissed the petition for lack of jurisdiction, ruling that under prevailing law (R.A. No. 8249), the Sandiganbayan exercises exclusive appellate jurisdiction over final judgments of RTCs in cases where the accused holds a position lower than Salary Grade 27. The CA denied petitioner’s motion for reconsideration.
ISSUE
Whether the Court of Appeals correctly dismissed petitioner’s petition for review for lack of jurisdiction, holding that the Sandiganbayan has exclusive appellate jurisdiction over her case.
RULING
Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed the CA’s dismissal. The jurisdiction of appellate courts is determined by law. At the time the crime was committed and during the proceedings, Republic Act No. 8249 governed. This law provides that the Sandiganbayan shall exercise exclusive appellate jurisdiction over final judgments, resolutions, or orders of Regional Trial Courts, whether in the exercise of their original or appellate jurisdiction, in cases where the accused holds a position lower than Salary Grade 27. Since petitioner held a position lower than Salary Grade 27, the proper avenue for appeal from the RTC decision affirming her MCTC conviction was to the Sandiganbayan, not the Court of Appeals. The negligence of petitioner’s former counsel in filing the appeal with the wrong court binds the client. Jurisdiction is conferred by law and cannot be vested by the parties’ agreement, waiver, or good faith. The Court of Appeals acted correctly in dismissing the petition for lack of jurisdiction.