G.R. No. 71163 -65 November 9, 1990
CARLITO P. BONDOC, petitioner, vs. THE HONORABLE SANDIGANBAYAN AND THE HONORABLE TANODBAYAN, respondents.

FACTS

Petitioner Carlito P. Bondoc, a private individual and Assistant Manager of Citibank, was charged with estafa through falsification of public documents as a co-principal with two Central Bank employees. The charges against the government employees (Criminal Cases Nos. 5949-5951) were filed earlier and assigned to the Sandiganbayan’s Second Division. The separate informations against Bondoc (Criminal Cases Nos. 9349-9351) were filed later and assigned to the Third Division. Bondoc moved to quash, arguing that under Section 4(3) of P.D. No. 1606, as amended, private individuals charged as co-principals with public officers must be tried jointly. He contended this requirement was mandatory and jurisdictional; thus, the Sandiganbayan lost jurisdiction by initiating separate proceedings.
The Third Division denied his motion, ruling the joint trial provision was not jurisdictional. To address his objection, it later referred his cases to the Second Division for consolidation. However, by that time, the trial of the cases against the government employees had already been terminated. The Second Division denied consolidation and returned the cases to the Third Division, noting the practical impossibility of a joint trial as the co-accused Vicente had a pending reinvestigation and opposed consolidation.

ISSUE

Whether the Sandiganbayan commits grave abuse of discretion by proceeding with a separate trial of a private individual charged as a co-principal with public officers, despite the provision in P.D. No. 1606 for a joint trial.

RULING

The Supreme Court denied the petition, upholding the Sandiganbayan’s jurisdiction. The Court ruled that the requirement for a joint trial under Section 4(3) of P.D. No. 1606 is directory, not mandatory or jurisdictional. The provision’s primary purpose is to avoid multiplicity of suits and prevent split jurisdiction, not to oust the Sandiganbayan of its authority. Jurisdiction is conferred by law based on the nature of the offense and the penalty involved. The crimes charged—estafa through falsification by public officers in conspiracy with private individuals, carrying penalties exceeding six years—fall within the Sandiganbayan’s exclusive original jurisdiction regardless of trial mode.
The Court emphasized that statutory construction favors the interpretation which gives effect to the law’s intent. Declaring the joint trial rule as jurisdictional would lead to absurdity, allowing a private accused to evade the Sandiganbayan’s jurisdiction simply by avoiding a joint trial. Since the offenses are within the Sandiganbayan’s exclusive jurisdiction, they cannot be transferred to regular courts. Bondoc’s argument about having a greater chance of acquittal in regular courts due to two appellate levels was deemed irrelevant, as the matter was settled in Nuñez v. Sandiganbayan. The Sandiganbayan did not commit grave abuse of discretion in proceeding with the separate trial.