GR L 61998; (February, 1983) (Digest)
G.R. No. L-61998 February 22, 1983
ROGELIO DE JESUS, petitioner, vs. PEOPLE OF THE PHILIPPINES, et al., respondents.
FACTS
Petitioner Rogelio de Jesus, the COMELEC Registrar of Casiguran, Sorsogon, was charged with election offenses under the 1978 Election Code for allegedly registering voters and issuing identification cards on election day and tampering with election reports. The complaint was initially filed with the Commission on Elections (COMELEC) but was endorsed to the Provincial Fiscal. Noting the charges were in relation to his office, deputized Tanodbayan prosecutors conducted the investigation and subsequently filed an information before the Sandiganbayan.
Petitioner filed a motion to quash the information, contending that the power to investigate, prosecute, and try election offenses is vested by law exclusively in the COMELEC and the Court of First Instance (now Regional Trial Court), not the Tanodbayan and Sandiganbayan. The COMELEC appeared as amicus curiae, supporting petitioner’s position. The Sandiganbayan denied the motion, asserting its jurisdiction over the case because the offenses were committed by a public officer in relation to his office.
ISSUE
Whether the Sandiganbayan and the Tanodbayan, or the COMELEC and the regular courts, have jurisdiction over election offenses committed by a public officer in relation to his office.
RULING
The Supreme Court ruled in favor of the petitioner, holding that jurisdiction over election offenses is vested exclusively in the COMELEC and the regular courts. The Court applied the principle of statutory construction that a special law prevails over a general law. The 1978 Election Code is a special law that specifically grants the COMELEC the power to conduct preliminary investigations and prosecute election offenses, and confers exclusive original jurisdiction to the courts of first instance to try and decide such cases. In contrast, the jurisdiction of the Sandiganbayan, as defined by its charter (P.D. No. 1606), is general, covering “other crimes or offenses committed by public officers … in relation to their office.”
The Court emphasized that the specific statutory grant of authority to the COMELEC and the regular courts must prevail over the general jurisdiction of the Sandiganbayan to avoid splitting jurisdiction, which would lead to confusion, unequal protection, and inconsistent decisions detrimental to the fair and speedy administration of justice. Consequently, the Sandiganbayan’s resolution was set aside, and the criminal case was dismissed. The COMELEC was directed to conduct the investigation and, if warranted, prosecute the case before the proper regional trial court.