FACTS:

In 1998, the Senate Blue Ribbon Committee investigated alleged anomalies at the Armed Forces of the Philippines-Retirement and Separation Benefit System (AFP-RSBS). The Committee found that when acquiring lands, the AFP-RSBS would execute two sets of deeds of sale - one showing a higher price and the other showing a discounted purchase price. The first set of deeds would be kept by the AFP-RSBS Legal Department while the second set would be held by the vendors. The vendors would then use these deeds of sale to secure titles in the name of AFP-RSBS, enabling the AFP-RSBS to draw more money from its funds and the vendors to pay lesser taxes. The Committee recommended the prosecution of General Jose Ramiscal, Jr. (Ret.), former AFP-RSBS president, for falsification of public documents and violation of Republic Act (R.A.) 3019. The Office of the Ombudsman filed criminal cases against several respondents in the Sandiganbayan. Two of the respondents filed a motion to dismiss on the ground that the Sandiganbayan had no jurisdiction over the case. The Sandiganbayan initially granted the motions but later changed its position, ruling that AFP-RSBS is a government-owned and controlled corporation. However, the Sandiganbayan held that the accused did not fall under the jurisdiction of the Sandiganbayan since they did not hold any of the government positions enumerated under the law. The Ombudsman petitioned the Supreme Court, arguing that the Sandiganbayan erred in holding that it has no jurisdiction over the case. The Supreme Court granted the petition, reversed the Sandiganbayan's decision, and directed the Sandiganbayan to reinstate the cases.

ISSUES:

1. Whether or not the Sandiganbayan erred in holding that it has no jurisdiction over offenses involving the heads of the legal departments of government-owned and controlled corporations.

RULING:

1. The Sandiganbayan erred in holding that it has no jurisdiction over the offenses involving the heads of the legal departments of government-owned and controlled corporations. The court ruled that the AFP-RSBS is a government-owned and controlled corporation. The accused, who held the position of Legal Department Head of AFP-RSBS, falls within the definition of "manager" as used in Section 4(a)(1)(g) of R.A. 8249. Therefore, the Sandiganbayan has jurisdiction over the case.

PRINCIPLES:

• The Sandiganbayan has exclusive original jurisdiction over cases involving violations of Republic Act No. 3019, as amended, otherwise known as the Anti-graft and Corrupt Practices Act, Republic Act No. 1379, and Chapter II, Section 2, Title VII, Book II of the Revised Penal Code, where one or more of the accused are officials occupying certain positions in the government.

• The term "manager" as used in Section 4(a)(1)(g) of R.A. 8249 refers to officers who have charge of a corporation and control of its businesses or of its branch establishments, divisions, or departments, and who are vested with a certain amount of discretion and independent judgment.

• The doctrine of noscitur a sociis may be applied to construe the meaning of a term or phrase in a statute by considering the company of words in which it is founded or with which it is associated.