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COMELEC v. TOMAS B. NOYNAY

FACTS:

The case deals with the issue of whether R.A. No. 7691 has stripped Regional Trial Courts (RTCs) of jurisdiction over election offenses punishable with imprisonment not exceeding six (6) years. The Commission on Elections (COMELEC) brought charges against the private respondents for violating Section 261(i) of the Omnibus Election Code. The cases were filed with Branch 23 of the Regional Trial Court of Allen, Northern Samar. However, the presiding judge of Branch 23 ordered the withdrawal of the cases, claiming that the Regional Trial Court lacks jurisdiction over them based on Section 32 of B.P. Blg. 129 as amended by R.A. No. 7691. The COMELEC and the COMELEC Regional Director filed motions for reconsideration, which were denied. The petitioner then filed a special civil action for certiorari with mandamus, contending that Regional Trial Courts have exclusive original jurisdiction over election offenses. The Office of the Solicitor General supported the petitioner's position, while the private respondents argued that R.A. No. 7691 stripped the Regional Trial Courts of jurisdiction over offenses with a penalty of not more than 6 years of imprisonment.

ISSUES:

  1. Whether the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts have exclusive jurisdiction over election offenses punishable with imprisonment not exceeding six (6) years.

  2. Whether the enactment of RA No. 7691 repealed the special provisions conferring exclusive jurisdiction to Regional Trial Courts and Sandiganbayan.

  3. Whether the Metropolitan Trial Court has jurisdiction over criminal election offenses.

  4. Whether the Supreme Court's decision in "Alberto -vs- Judge Juan Lavilles, Jr." supports the petitioner's argument.

RULING:

  1. No, the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts do not have exclusive jurisdiction over election offenses punishable with imprisonment not exceeding six (6) years. The exception provided in Section 32 of B.P. Blg. 129 states that these lower courts' exclusive original jurisdiction does not cover criminal cases falling within the exclusive original jurisdiction of Regional Trial Courts and Sandiganbayan, regardless of the penalty prescribed. Election offenses, as stated in Morales v. Court of Appeals, fall within this exception.

  2. No, RA No. 7691 did not repeal the special provisions conferring exclusive jurisdiction to Regional Trial Courts and Sandiganbayan. R.A. No. 7691 is merely an amendatory law that did not touch the opening sentence of Section 32 of B.P. Blg. 129, which provides the exception to the exclusive jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts. Therefore, the special provisions specifying exclusive original jurisdiction of Regional Trial Courts and Sandiganbayan for certain cases still stand.

  3. The Supreme Court ruled that the Metropolitan Trial Court does not have jurisdiction over criminal election offenses. Such offenses are exclusively within the jurisdiction of the Regional Trial Court, except for offenses relating to failure to register or vote.

  4. The Supreme Court found that the petitioner misquoted and misrepresented the text of the decision in "Alberto -vs- Judge Juan Lavilles, Jr." The quoted portion was not the Court's own findings or rulings but was part of the memorandum of the Court Administrator cited in the decision.

PRINCIPLES:

  • The exclusive jurisdiction of courts is conferred by the Constitution or by Congress. Congress has the power to define, prescribe, and apportion the jurisdiction of various courts.

  • A special law must be construed as an exception to the general law on jurisdiction of courts.

  • The Judiciary Reorganization Act of 1980 remains in effect and was not repealed by R.A. No. 7691.

  • Jurisdiction over criminal election offenses is exclusively vested in the Regional Trial Court, except for offenses relating to failure to register or vote.

  • Lawyers have a duty not to knowingly misquote or misrepresent the text of a decision or authority, as mandated by Rule 10.02 of Canon 10 of the Code of Professional Responsibility.