GR L 50581; (January, 1982) (Digest)
G.R. Nos. L-50581-50617, January 30, 1982
RUFINO V. NUÑEZ, petitioner, vs. SANDIGANBAYAN and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Rufino V. Nuñez, a public official, was charged before the Sandiganbayan with multiple counts of estafa through falsification of public and commercial documents, allegedly committed in connivance with other co-accused public officials. The informations were filed in February and March 1979. Upon arraignment in May 1979, Nuñez filed a motion to quash the informations, challenging the constitutionality of Presidential Decree No. 1486, as amended, which created the Sandiganbayan. He argued that the decree violated his constitutional rights. The Sandiganbayan denied his motion and subsequent motion for reconsideration.
This prompted Nuñez to file a petition for certiorari and prohibition before the Supreme Court. He contended that Presidential Decree No. 1486, which established the Sandiganbayan as a special court with jurisdiction over graft and corruption cases involving public officers, was unconstitutional. Specifically, he alleged that the decree violated the due process, equal protection, and ex post facto clauses of the Constitution.
ISSUE
The primary issue is whether Presidential Decree No. 1486, as amended, creating the Sandiganbayan, is unconstitutional for allegedly violating the due process, equal protection, and ex post facto clauses.
RULING
The Supreme Court dismissed the petition and upheld the constitutionality of Presidential Decree No. 1486, as amended. The Court ruled that the legislative power of the President to create the Sandiganbayan during the period of martial law was recognized under the 1973 Constitution and its 1976 Amendments, affirming the ruling in Aquino Jr. v. Commission on Elections.
On the equal protection challenge, the Court held that the classification establishing a special court for public officers charged with graft was reasonable and based on substantial distinctions. The law was designed to address the pervasive evil of corruption in public service, a legitimate state interest. The classification applies equally to all persons under similar circumstances—public officers accused of graft—and does not constitute favoritism or undue preference.
Regarding the ex post facto claim, the Court found no merit. The law creating the Sandiganbayan is procedural, governing the jurisdiction and conduct of trials. It does not criminalize an act that was innocent when done, nor does it aggravate a crime, increase punishment, or alter the rules of evidence to the accused’s disadvantage. Procedural changes do not constitute ex post facto laws. The petition failed to demonstrate any constitutional infirmity in the decree. The Sandiganbayan was validly constituted to promote morality in public administration, a constitutional imperative under the principle that a public office is a public trust.