CENITA M. CARIAGA v. PEOPLE

FACTS:

In this case, Cenita Cariaga (petitioner) was charged before the Regional Trial Court (RTC) of Cauayan City in Isabela with three counts of malversation of public funds. The charges stemmed from her alleged misappropriation and conversion of public funds, specifically real property taxes, while she was serving as the municipal treasurer of Cabatuan, Isabela. The first case, Criminal Case No. 1293, involved an amount of P2,785.00, while the second and third cases, Nos. 1294 and 1295, involved amounts of P25,627.38 and P20,735.13, respectively. The Cauayan RTC found the petitioner guilty and sentenced her to prison, payment of fines, and perpetual special disqualification. Petitioner filed a Notice of Appeal with the intention of appealing the RTC's decision to the Court of Appeals. However, the Court of Appeals dismissed petitioner's appeal for lack of jurisdiction, explaining that the Sandiganbayan has exclusive appellate jurisdiction over the offense of malversation of public funds.

ISSUES:

  1. Whether the Court of Appeals has jurisdiction over the appeal of the petitioner.

  2. Whether the Sandiganbayan has exclusive appellate jurisdiction over the offense of malversation of public funds committed by a municipal treasurer with a salary grade below 27.

RULING:

  1. The Court of Appeals does not have jurisdiction over the appeal of the petitioner.

  2. The Sandiganbayan has exclusive appellate jurisdiction over the offense of malversation of public funds committed by a municipal treasurer with a salary grade below 27.

PRINCIPLES:

  • Jurisdiction over the offense of malversation of public funds is vested in the Sandiganbayan, to the exclusion of all other courts. (Presidential Decree No. 1606, as amended by Republic Act No. 8249)

  • The Sandiganbayan has exclusive appellate jurisdiction over offenses committed by public officials or employees with a salary grade of 27 or lower, including malversation of public funds. (Presidential Decree No. 1606, as amended by Republic Act No. 8249)