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LICERIO A. ANTIPORDA v. FRANCIS E. GARCHITORENA

FACTS:

The accused, Licerio A. Antiporda, Jr., Eliterio Rubiaco, Victor Gascon, and Caesar Talla, were charged with the crime of kidnapping Elmer Ramos. The prosecution was ordered to submit an amendment to the Information, which they complied with and was admitted by the Sandiganbayan. The accused filed various motions, including an Urgent Omnibus Motion for reinvestigation and deferral of arrest warrants, a Motion for New Preliminary Investigation and to Hold in Abeyance and/or Recall Warrant of Arrest Issued, and a Motion to Quash the Amended Information for lack of jurisdiction. These motions were denied by the Sandiganbayan, which issued an order stating that it had jurisdiction over the offense charged. A motion for reconsideration was also denied, leading the accused to file a Petition for Certiorari and Prohibition with the Supreme Court.

ISSUES:

  1. Whether the Sandiganbayan had jurisdiction to take cognizance of the case.

  2. Whether the Sandiganbayan had jurisdiction over the offense charged.

  3. Whether the Sandiganbayan has jurisdiction over the case and if a reinvestigation is necessary.

RULING:

  1. The Sandiganbayan had jurisdiction to take cognizance of the case. Jurisdiction is the power of courts to hear and decide cases. For a court to have authority to dispose of a case on its merits, it must acquire jurisdiction over the subject matter and the parties. The Sandiganbayan exercises exclusive original jurisdiction in cases involving offenses committed by public officers and employees in relation to their office, including those employed in government-owned or controlled corporations, where the penalty prescribed by law is higher than prision correccional or imprisonment for six (6) years, or a fine of P6,000.00. In the present case, the Sandiganbayan had territorial jurisdiction over the case, and the petitioners voluntarily submitted to the court's authority when they filed a motion to quash.

  2. The Sandiganbayan did not have jurisdiction over the offense charged. The original information filed with the Sandiganbayan did not mention that the offense committed by the accused was office-related. It was only after the information was filed that the prosecution realized the omission of a jurisdictional fact. However, the petitioners are estopped from assailing the jurisdiction of the Sandiganbayan because they themselves challenged the jurisdiction of the Regional Trial Court in their motion for reconsideration, stating that the crime is work-related.

  3. Yes, the Sandiganbayan has jurisdiction over the case due to estoppel. The court has the authority to order the amendment of the Information. A reinvestigation is not necessary as the accused's substantial rights would not be impaired. The purpose of a preliminary investigation has already been achieved.

PRINCIPLES:

  • Jurisdiction is the power with which courts are invested for administering justice, including hearing and deciding cases.

  • A court acquires jurisdiction to try a criminal case when the offense is one which the court is authorized to take cognizance of, the offense was committed within its territorial jurisdiction, and the person charged with the offense has been brought into its forum for trial.

  • The Sandiganbayan exercises not only civil but also criminal jurisdiction, with criminal jurisdiction defined as the authority to hear and try a particular offense and impose the punishment for it.

  • A court can acquire jurisdiction over the persons of the accused either through the enforcement of warrants of arrest or their voluntary submission to the court.

  • Estoppel may prevent a party from assailing the jurisdiction of a court if that party has previously challenged the jurisdiction of a different court and voluntarily submitted to the court's authority.

  • A party cannot invoke the jurisdiction of a court to secure affirmative relief against his opponent and then question the same jurisdiction afterwards.

  • Rule 110, Section 14 of the Rules of Court allows for the amendment of the information or complaint, in substance or form, before the accused pleads.

  • A reinvestigation is proper only if the accused's substantial rights would be impaired.

  • A preliminary investigation is inquisitorial in nature and is held to determine whether a crime has been committed and whether there is probable cause to believe that the accused is guilty.

  • An offense is considered committed in relation to office if it is intimately connected with the respective offices of the accused and was perpetrated while they were in the performance of their official functions.