G.R. No. 234670-71 August 14, 2019
Omar Erasmo Gonowon Ampongan, Petitioner, vs. Hon. Sandiganbayan, People of the Philippines, and Ombudsman Special Prosecutor, Respondents.

FACTS

Petitioner Omar Erasmo Gonowon Ampongan, then Vice-Mayor of Iriga City with Salary Grade 26, was charged before the Sandiganbayan with two offenses: (1) violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) and (2) Falsification of Public Document under Article 171(2) of the Revised Penal Code. The charges stemmed from his 2014 appointment of Edsel Dimaiwat as Secretary to the Sangguniang Panlungsod, allegedly without the required screening by the Personnel Selection Board and by falsifying the CSC appointment form to indicate such screening had occurred.
Petitioner filed a Motion to Quash the Informations, arguing the Sandiganbayan lacked jurisdiction. He contended that the Informations did not allege damage to the government exceeding One Million Pesos, which under R.A. No. 10660 would vest jurisdiction with the Regional Trial Court. Alternatively, he argued that under the applicable law at the time of the offense (R.A. No. 8249), his position as Vice-Mayor (Salary Grade 26) was outside the Sandiganbayan’s jurisdiction. The Sandiganbayan denied the motion, ruling that the One Million Pesos threshold applied only to offenses committed after May 15, 2015, and that the position of City Vice-Mayor is expressly within its jurisdiction under the law.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in holding that it has jurisdiction over the offenses charged and over the person of the petitioner.

RULING

The Supreme Court dismissed the petition and affirmed the Sandiganbayan’s Order. The Court held that the Sandiganbayan correctly assumed jurisdiction. First, the Court clarified that the jurisdictional requirement of alleging damage exceeding One Million Pesos under Section 4 of R.A. No. 10660 applies prospectively only to offenses committed after its effectivity on May 15, 2015. Since the alleged acts were committed in 2014, the governing law was R.A. No. 8249, which did not contain such a monetary threshold for jurisdiction.
Second, the Court ruled that petitioner, as City Vice-Mayor, falls under the Sandiganbayan’s jurisdiction as defined in Section 4 of R.A. No. 8249. The law explicitly grants the Sandiganbayan jurisdiction over officials occupying positions with Salary Grade 27 or higher, and specifically over provincial and city officials, such as vice-mayors, regardless of salary grade. Furthermore, jurisdiction is determined by the allegations in the Information. The Informations sufficiently alleged that the offenses were committed by petitioner “in relation to his office” and while “in the performance of his official functions,” which satisfies the jurisdictional requirement for offenses falling under the Sandiganbayan’s purview. The Sandiganbayan’s denial of the Motion to Quash was thus legally sound and not tainted with grave abuse of discretion.