G.R. No. 251177, September 08, 2020
ALFREDO J. NON, GLORIA VICTORIA C. YAP-TARUC, JOSEFINA PATRICIA A. MAGPALE-ASIRIT AND GERONIMO D. STA. ANA, PETITIONERS, VS. OFFICE OF THE OMBUDSMAN, ALYANSA PARA SA BAGONG PILIPINAS, INC., AND HON. MARIA GRACIA A. CADIZ-CASACLANG, PRESIDING JUDGE, BRANCH 155, REGIONAL TRIAL COURT, PASIG CITY, RESPONDENTS.

FACTS

Petitioners, former Commissioners of the Energy Regulatory Commission (ERC), were charged before the Regional Trial Court (RTC) of Pasig City for violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act). The criminal Information alleged they gave unwarranted benefit to MERALCO by issuing Resolution No. 1, Series of 2016, which postponed the effectivity of a rule requiring a Competitive Selection Process (CSP) for power supply agreements. This allowed MERALCO to file agreements with affiliates without a CSP. Petitioners moved to quash the Information, arguing the RTC Pasig lacked jurisdiction under R.A. No. 10660, which mandates that cases against public officials with Salary Grade 27 and higher be tried in a judicial region other than where they hold office.
The RTC denied the motion to quash, ruling that the Supreme Court had not yet promulgated the implementing rules for the venue provision of R.A. No. 10660. It held that, absent such rules, the default venue under the Rules of Criminal Procedure—where the offense was committed—applied. Since the Information alleged the offense was committed in Pasig City in relation to their official functions at the ERC, which is located in Pasig, the RTC Pasig asserted jurisdiction.

ISSUE

Whether the Regional Trial Court of Pasig City has jurisdiction to try the criminal case against the petitioners.

RULING

No. The Supreme Court granted the petition and annulled the RTC Pasig City’s orders. The Court held that R.A. No. 10660 is a substantive law on jurisdiction and venue that is self-executing and does not require implementing rules to be effective. The law explicitly states that cases falling under its provisions “shall be tried in a judicial region other than where the official holds office.” The ERC’s principal office is in Pasig City; therefore, the case cannot be tried in Pasig or anywhere within the National Capital Judicial Region.
The RTC’s reliance on the absence of Supreme Court rules was a grave error. Jurisdictional laws are immediately operative. The default rules on venue in the Rules of Criminal Procedure apply only when no specific statute provides otherwise. Here, R.A. No. 10660 provides a specific, mandatory rule on venue for cases involving high-ranking public officials. Since the RTC Pasig was not the proper court as mandated by the special law, it acted without jurisdiction. Consequently, all its proceedings were null and void. The criminal case was ordered dismissed, without prejudice to its refiling in the proper court.