Inocentes vs. People case digest - remedial law 1- criminal procedure , G.R. No. 205963-64, July 7, 2016

 

Inocentes vs. People, G.R. No. 205963-64, July 7, 2016

Facts: Inocentes and 4 other public officers, being the Branch Manager, Division Chief III, Property Appraiser III, and Senior General Insurance Specialist of GSIS conspiring and confederating with De Guzman by approving the housing loans of 491 borrowers of De Guzman’s housing project under the GSIS Bahay Ko Program, with a total amount of loans amounting to Php 241M, knowing fully well that the said borrowers were not qualified and were not under the territorial jurisdiction of the Tarlac City, thereby giving said borrowers unwarranted benefit and causing damage and prejudice to the government and to public interest in the said amount and granting loans under the GSIS Bahay Ko Program to 53 borrowers of De Guzman’s land development project amounting to Php52M, despite the knowledge of the fact that the lots covered were intended for commercial purposes and by causing the over-appraisal of the land and buildings offered as collaterals, thus causing undue injury to the Government.

Sandiganbayan maintained its jurisdiction over the case because Section 4 of P.D. 1606, as amended by R.A. No. 8249, specifically includes managers of GOCCs – whose position may not fall under Salary Grade 27 or higher – who violate R.A. No. 3019.

Issue: Whether or not Sandiganbayan have jurisdiction over the case as Inocentes held a position with a Salary Grade of 26.

Held: Violations of R.A. No. 3019 committed by presidents, directors or trustees, or managers of government-owned or -controlled corporations, and state universities shall be within the exclusive original jurisdiction of the Sandganbayan. Sandiganbayan maintains its jurisdiction over those officials specifically enumerated in (a) to (g) of Section 4(1) of P.D. No. 1606, as amended, regardless of their salary grades. Simply put, those that are classified as Salary Grade 26 and below may still fall within the jurisdiction of the Sandiganbayan, provided they hold the positions enumerated by the law. In this category, it is the position held, not the salary grade, which determines the jurisdiction of the Sandiganbayan.

Furthermore, as the Sandiganbayan correctly held, even low-level management positions fall under the jurisdiction of the Sandiganbayan.

Sandiganbayan was correct in denying Inocentes’ motion to quash; hence, there was no grave abuse in the exercise of its discretion regarding this matter.

The Sandiganbayan is ORDERED to DISMISS the case against Inocentes for violating Inocentes' right to a speedy disposition of his case.