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ANGELITO P. MAGNO v. PEOPLE

FACTS:

The petitioner, Angelito P. Magno, filed a petition for review on certiorari seeking the reversal of the Amended Decision of the Court of Appeals (CA), which denied the petition for certiorari and upheld the ruling of the Regional Trial Court (RTC) that precluded Atty. Adelino B. Sitoy from acting as private prosecutor in Criminal Case No. DU-10123. The case stemmed from the Office of the Ombudsman filing an information for multiple frustrated murder and double attempted murder against several accused, including Magno, who were public officers working under the National Bureau of Investigation. During the arraignment, Magno objected to the formal appearance and authority of Atty. Sitoy as the private prosecutor for the Office of the Ombudsman. The RTC ruled in favor of the Ombudsman, but the CA later allowed the private prosecutor to appear for the petitioner in the prosecution of the civil aspect of the case. Magno argued that the CA did not have jurisdiction and that the Ombudsman cannot deputize private practitioners to prosecute cases. The Ombudsman countered that the private prosecutor could intervene in the case based on the Rules of Court.

ISSUES:

  1. Whether the Sandiganbayan or the Court of Appeals (CA) has appellate jurisdiction over the Regional Trial Court's (RTC) decision regarding the authority of Atty. Sitoy to prosecute the case on behalf of the Ombudsman.

  2. Whether the Court of Appeals (CA) had jurisdiction to issue its Amended Decision in the case.

  3. Whether the principle of estoppel can cure the jurisdictional defect of the Office of the Ombudsman's petition before the CA.

RULING:

  1. The Sandiganbayan has appellate jurisdiction over the RTC's decision not to allow Atty. Sitoy to prosecute the case on behalf of the Ombudsman.

  2. The CA's Amended Decision is declared null and void because it was issued without jurisdiction. Jurisdiction over a subject matter is conferred by law, and any judgment, order, or resolution issued without it is void and cannot be given effect. Lack of jurisdiction over the subject matter may be interposed at any time, even after final judgment. The CA should have considered the argument of lack of jurisdiction raised by the petitioner.

  3. The principle of estoppel cannot be relied upon by the Office of the Ombudsman to cure the jurisdictional defect of its petition before the CA. Even if the issue of lack of jurisdiction had been raised only on appeal to the Supreme Court, the CA's lack of jurisdiction could not be cured. The principle of estoppel on the question of jurisdiction depends on whether the lower court actually had jurisdiction or not. If the lower court had no jurisdiction, the parties are not barred from assailing such jurisdiction on appeal. However, if the lower court had jurisdiction and the case was heard and decided upon a given theory, the party that induced the adoption of such theory will not be permitted to assume an inconsistent position on appeal.

PRINCIPLES:

  • Presidential Decree No. 1606 establishes the Sandiganbayan's jurisdiction, including its exclusive appellate jurisdiction over final judgments, resolutions, or orders of the RTC.

  • The Sandiganbayan has exclusive original jurisdiction over petitions for the issuance of writs and other ancillary writs and processes in aid of its appellate jurisdiction, including certiorari.

  • Private individuals charged as co-principals, accomplices, or accessories with public officers or employees shall be tried jointly with said public officers and employees in the proper courts, which shall exercise exclusive jurisdiction over them.

  • Any provision of law or Rules of Court to the contrary notwithstanding, the criminal action and the corresponding civil action for the recovery of civil liability shall at all times be simultaneously instituted with and jointly determined in the same proceeding by the Sandiganbayan or appropriate courts. The separate civil action shall be deemed abandoned if not consolidated and jointly determined with the criminal action.

  • Jurisdiction is conferred by law, and any judgment, order, or resolution issued without jurisdiction is void. Lack of jurisdiction over the subject matter may be interposed at any time, including after final judgment.

  • Estoppel does not confer jurisdiction over a cause of action to a tribunal where none exists by law. The principle of estoppel on the question of jurisdiction depends on whether the lower court actually had jurisdiction or not. If it had no jurisdiction and the case was tried and decided upon the theory that it had jurisdiction, the parties are not barred from assailing such jurisdiction on appeal. However, if the lower court had jurisdiction and the case was heard and decided upon a given theory, the party who induced the adoption of such theory will not be permitted to assume an inconsistent position on appeal.