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FLEURDELIZ B. ORGANO v. SANDIGANBAYAN

FACTS:

The case involves a Petition for Habeas Corpus filed by the petitioner, seeking the release of her mother who was detained pursuant to a Warrant of Arrest issued by the Sandiganbayan in connection with a case of plunder. The accused, including the petitioner's mother, were charged with committing plunder by amassing and acquiring funds belonging to the National Government. The petitioner argues that the Sandiganbayan has no jurisdiction over her mother as none of the accused occupy positions corresponding to Salary Grade 27 or higher. The Sandiganbayan issued a warrant of arrest against the accused, which led to the detention of the petitioner's mother. The petitioner filed various motions, but the Sandiganbayan denied them and ruled that it had jurisdiction over the case and over the petitioner's mother, who was considered a fugitive from justice. The petitioner then filed a petition for certiorari and prohibition before the Supreme Court, questioning the jurisdiction of the Sandiganbayan.

(Note: The partial digest only includes the section on "FACTS".)

ISSUES:

  1. Whether the Sandiganbayan has jurisdiction over cases of plunder regardless of the public official's salary grade.

  2. Whether Republic Act No. 8249 impliedly repealed Republic Act No. 7080.

  3. Whether or not the Sandiganbayan has jurisdiction over the case.

  4. Whether or not the petitioner's filing of a petition for habeas corpus constitutes forum shopping.

RULING:

  1. The Sandiganbayan does not have jurisdiction over cases of plunder regardless of the public official's salary grade. The jurisdiction of the Sandiganbayan is limited to cases where the accused public official occupies a Salary Grade of '27' or above, as prescribed in Republic Act No. 8249.

  2. Republic Act No. 8249 impliedly repealed Republic Act No. 7080, thereby conferring jurisdiction over plunder cases exclusively to the Sandiganbayan when the accused is a public official with Salary Grade 27 or higher.

  3. The Sandiganbayan does not have jurisdiction over the case. The Sandiganbayan's jurisdiction is limited to cases involving violations of specific laws and offenses committed by public officials and employees enumerated in the law. The jurisdiction of the Sandiganbayan is determined by the prescribed penalty and the rank of the public official or employee. In this case, the petitioner's mother is not within the prescribed ranks and the offense committed does not fall within the laws covered by the Sandiganbayan's jurisdiction.

  4. Although there is no forum shopping since the petitioner was not a party in another case, the Court expresses its displeasure at the attempt to seek the same relief in two different cases. The Court notes that a motion in the other case would have accomplished the same result more expeditiously and would have avoided wastage of the court's time and resources.

PRINCIPLES:

  • A special law will prevail over a statute or law of general application.

  • When a special law provides for the jurisdiction of a court, that law will prevail over provisions of a different law that may be considered general in nature.

  • Prosecutions for plunder are cognizable by the Sandiganbayan only when the accused is a public official with Salary Grade 27 or higher.

  • The jurisdiction of the Sandiganbayan is limited to cases involving violations of specific laws and offenses committed by public officials and employees enumerated in the law.

  • The jurisdiction of the Sandiganbayan is determined by the prescribed penalty and the rank of the public official or employee.

  • Filing multiple petitions for the same relief, even if not technically considered forum shopping, may still be viewed unfavorably by the court.