G.R. No. 56384 . March 22, 1984.
MAYOR FRANCISCO LECAROZ, Petitioner, vs. SANDIGANBAYAN, Respondent.

FACTS

Petitioner Francisco Lecaroz, the Mayor of Sta. Cruz, Marinduque, was charged before the Sandiganbayan with the crime of Grave Coercion. The information alleged that on July 2, 1979, he took advantage of his public position by taking over the operation and control of a gasoline station owned by Pedro Par, selling the gasoline, and padlocking the dispensing pump without legal authority, thereby depriving Par of his lawful trade. An amended information later specified he did so “by ordering his policemen companions.”
Lecaroz filed a motion to quash, arguing the Sandiganbayan lacked jurisdiction because the offense was not committed in relation to his office and Grave Coercion was not among the offenses specifically enumerated under the law defining the Sandiganbayan’s jurisdiction. He further contended that, assuming jurisdiction, the Sandiganbayan committed grave abuse of discretion by denying his request to transfer the case to the Court of First Instance of Marinduque for the convenience of witnesses. The Sandiganbayan denied his motion, prompting this certiorari petition.

ISSUE

The primary issue is whether the Sandiganbayan has jurisdiction over the crime of Grave Coercion as charged against a municipal mayor, where the acts were allegedly committed in relation to his office.

RULING

The Supreme Court dismissed the petition, upholding the Sandiganbayan’s jurisdiction. The Court explained that Section 5, Article XIII of the 1973 Constitution created the Sandiganbayan and vested it with jurisdiction not only over graft and corrupt practices but also over “such other offenses committed by public officers and employees… in relation to their office as may be determined by law.” This constitutional provision explicitly delegated to the lawmaking body the power to determine these “other offenses.”
Pursuant to this delegation, Presidential Decree No. 1486, as amended, provided in Section 4(c) that the Sandiganbayan’s jurisdiction includes “other crimes or offenses committed by public officers or employees… in relation to their office.” The Court held that this legislative determination was within constitutional bounds and not subject to judicial review on policy grounds. The allegations in the information were sufficient to establish a relation to office, as it was specifically averred that Lecaroz, “taking advantage of his public position” and “by ordering his policemen companions,” committed the acts. His mayoral authority was the alleged means by which the coercion was effected.
The Court also found no grave abuse of discretion in denying the transfer of venue. Under the applicable laws, the Sandiganbayan had concurrent jurisdiction with regular courts over the offense. Applying the rule on concurrent jurisdiction, the court that first acquires jurisdiction (the Sandiganbayan, by the filing of the information) exercises it to the exclusion of others. The subsequent amendment by P.D. No. 1861, which would have transferred such cases to regular courts, was not retroactive and did not affect this case filed in 1980. The petition was dismissed for lack of merit.