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PEOPLE v. SANDIGANBAYAN

FACTS:

The petitioner, represented by the Office of the Special Prosecutor (OSP), filed a petition for certiorari arguing that the Sandiganbayan has jurisdiction over officers of government-owned or controlled corporations (GOCCs) organized and incorporated under the Corporation Code for purposes of the Anti-Graft and Corrupt Practices Act. The respondent, Efren L. Alas, was charged with violation of RA 3019 for allegedly entering into anomalous advertising contracts as the President and Chief Operating Officer of the Philippine Postal Savings Bank (PPSB). Alas filed a motion to quash the information for lack of jurisdiction, asserting that PPSB was a private corporation and its officers do not fall under the jurisdiction of the Sandiganbayan. The Sandiganbayan ruled in favor of Alas, citing that PPSB was organized and incorporated under the Corporation Code and was registered with the SEC. The OSP filed a petition arguing that PPSB qualifies as a government-owned or controlled corporation under the Administrative Code of 1987. Respondent Alas maintained that PPSB was not created by special law, and therefore its officers did not fall within the jurisdiction of the Sandiganbayan. The Supreme Court agreed with the OSP, holding that PPSB qualified as a government-owned or controlled corporation and that the manner of creation of GOCCs was not a distinguishing factor for determining the jurisdiction of the Sandiganbayan. Thus, Alas, as an officer of PPSB, falls under the jurisdiction of the Sandiganbayan.

ISSUES:

  1. Does the Sandiganbayan have jurisdiction over presidents, directors or trustees, or managers of government-owned or controlled corporations organized and incorporated under the Corporation Code for purposes of the provisions of RA 3019?

RULING:

  1. Yes, the Sandiganbayan has jurisdiction over presidents, directors or trustees, or managers of government-owned or controlled corporations organized and incorporated under the Corporation Code for purposes of the provisions of RA 3019. The Sandiganbayan has jurisdiction over public officers, and private persons charged with public officers in the commission of offenses, as stated in the Republic Act as well as Presidential Decree No. 1606 as amended by President Decree No. 1486 and Republic Act No. 7975 and Republic Act No. 8249. Although the Philippine Postal Savings Bank (PPSB) is not created by a special law, it is a subsidiary of the Philippine Postal Corporation which is a government-owned corporation. Therefore, its officers, including respondent Alas, fall under the jurisdiction of the Sandiganbayan.

PRINCIPLES:

  • The Sandiganbayan has jurisdiction over public officers and private persons charged with public officers in the commission of offenses. (Republic Act as well as Presidential Decree No. 1606, as amended by President Decree No. 1486 and Republic Act No. 7975 and Republic Act No. 8249)

  • Government-owned or controlled corporations created by special charter are subject to the Civil Service Law, while those incorporated under the general corporation law are not within its coverage. (Trade Unions of the Philippines and Allied Services vs. National Housing Corp., 173 SCRA 33)

  • The manner of creation of a government-owned or controlled corporation determines whether it falls under the jurisdiction of the Civil Service Law. (Philippine National Oil Company Energy Development Corporation vs. Leogardo, 175 SCRA 26)

  • Officers of a government-owned or controlled corporation organized as a subsidiary of a government-owned or controlled corporation under the general corporation law are not considered public officers. (Davao City Water District vs. Civil Service Commission, 201 SCRA 601)