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PANFILO M. LACSON v. EXECUTIVE SECRETARY

FACTS:

Petitioner Panfilo Lacson, along with petitioners-intervenors Romeo Acop and Francisco Zubia, Jr., challenged the constitutionality of Sections 4 and 7 of Republic Act No. 8249, which redefined the jurisdiction of the Sandiganbayan. This challenge emerged after eleven alleged members of the Kuratong Baleleng gang, suspected of involvement in organized crime and bank robberies, were killed along Commonwealth Avenue in Quezon City on May 18, 1995, by police officers from the Anti-Bank Robbery and Intelligence Task Group (ABRITG), headed by Chief Superintendent Jewel Canson. Following a media revelation by SPO2 Eduardo delos Reyes that the incident was a summary execution rather than a shootout, the Ombudsman initiated an investigation, leading to the indictment of Lacson and others for multiple murder. Initial absolution of the accused by a panel led by Deputy Ombudsman Bienvenido Blancaflor was reversed by a review board headed by Francisco Villa, recommending indictments for multiple murder, which was approved by the Ombudsman with modifications. Lacson and others challenged the Sandiganbayan's jurisdiction, asserting that under the amended information, the cases fell under the Regional Trial Court's purview since none of the principal accused held positions that met the Sandiganbayan’s jurisdictional requirements. Despite initial resolutions by the Sandiganbayan transferring the cases to the Regional Trial Court, the enactment of R.A. 8249 during pending motions for reconsideration led the Sandiganbayan to retain jurisdiction, prompting the petitioners to contest the law’s constitutionality and its retroactive application, which they argued violated due process and equal protection. Further, intervenors contended that the law essentially targeted their specific cases, introducing ex post facto elements and procedural disadvantages relative to their rights under the prior legal framework.

ISSUES:

  1. Constitutionality of Sections 4 and 7 of Republic Act No. 8249

    • Does Section 4 of R.A. 8249, which defines the jurisdiction of the Sandiganbayan, violate the constitutional rights to equal protection and procedural due process?

    • Does Section 7 of R.A. 8249, which applies the law to all cases where trial has not begun, constitute an ex post facto law?

  2. Jurisdiction of the Sandiganbayan

    • Does the Sandiganbayan have jurisdiction over the multiple murder cases charged against petitioner and intervenors under the amended informations, considering their ranks and the offenses charged?

RULING:

  1. Constitutionality of Sections 4 and 7 of Republic Act No. 8249

    • The Supreme Court upheld the constitutionality of Sections 4 and 7 of R.A. 8249. The court found no violation of the right to equal protection and procedural due process. The Court also held that R.A. 8249 is not an ex post facto law as it is not penal in nature and merely pertains to jurisdictional matters.

  2. Jurisdiction of the Sandiganbayan

    • The amended informations for murder did not sufficiently allege that the offenses were committed in relation to the accused police officers' official functions. Thus, the Supreme Court ruled that the exclusive original jurisdiction lies with the Regional Trial Court of Quezon City, not the Sandiganbayan.

PRINCIPLES:

  1. Presumption of Constitutionality:

    • Every law carries with it the presumption of constitutionality. The burden of proving a law’s invalidity lies with the party challenging it.

  2. Equal Protection Clause:

    • Legislation based on reasonable classification does not violate the equal protection clause. The classification must (a) rest on substantial distinctions, (b) be germane to the purpose of the law, (c) not be limited to existing conditions only, and (d) apply equally to all members of the same class.

  3. Ex Post Facto Law:

    • An ex post facto law pertains to laws which (a) make an act criminal which was not criminal when done, (b) increase the punishment of an act, (c) change the rules of evidence to the detriment of the accused, or (d) alter the legal situation to the disadvantage of the accused. Jurisdictional or procedural changes are generally not ex post facto.

  4. Jurisdictional Determination:

    • Jurisdiction of a court is determined by the allegations in the complaint or information, not by the evidence presented during trial.

  5. Intimate Relation to Office:

    • For an offense to fall under the jurisdiction of the Sandiganbayan, it must be alleged and proven that the offense was committed in intimate relation to the accused’s official duties.

  6. Right to Appeal:

    • The right to appeal is statutory. Changes in procedural laws affecting the appellate process do not constitute an ex post facto law and do not infringe upon vested rights.