TL;DR

In a decisive ruling, the Supreme Court clarified that Regional Trial Courts (RTCs) trying graft cases against high-ranking public officials must adhere to the venue provisions of Republic Act No. 10660 (RA 10660) immediately, even without specific implementing rules from the Court. The decision emphasizes that cases falling under the RTC’s jurisdiction due to the amount of alleged damage or absence of bribery must be tried in a judicial region other than where the official holds office. This ensures impartiality and prevents undue influence. The Court underscored that statutory jurisdiction and venue are immediately effective upon the law’s effectivity, and procedural rules cannot override substantive legal mandates. This ruling practically means that public officials facing graft charges in RTCs are entitled to be tried in a different judicial region, promoting fairness and deterring local pressures.

Beyond Local Courts: The Fight for Proper Venue in the ERC Commissioners’ Graft Case

This case revolves around a petition filed by former Energy Regulatory Commission (ERC) Commissioners Alfredo J. Non, Gloria Victoria C. Yap-Taruc, Josefina Patricia A. Magpale-Asirit, and Geronimo D. Sta. Ana, challenging the jurisdiction of the Regional Trial Court (RTC) of Pasig City. The commissioners were charged with violating Section 3(e) of the Anti-Graft and Corrupt Practices Act for allegedly giving unwarranted benefits to Manila Electric Company (MERALCO) by delaying the implementation of a resolution requiring competitive bidding for power supply agreements. The core legal question is whether the RTC of Pasig City, where the ERC office is located, had the proper venue to try the case, considering Republic Act No. 10660, which mandates that cases against officials triable by the RTC should be heard in a judicial region different from their official station. This case highlights the tension between procedural rules and statutory law in determining the correct venue for criminal proceedings against public officials.

The petitioners argued that under RA 10660, the RTC Pasig City lacked jurisdiction because the law explicitly requires such cases to be tried in a judicial region outside the National Capital Judicial Region, where they held office. They cited Section 2 of RA 10660, amending Presidential Decree No. 1606, which states:

Subject to the rules promulgated by the Supreme Court, the cases falling under the jurisdiction of the Regional Trial Court under this section shall be tried in a judicial region other than where the official holds office.

The RTC, however, denied their Motion to Quash, reasoning that since the Supreme Court had not yet issued implementing rules for RA 10660, the general rule on venue under the Rules of Criminal Procedure should apply – that is, the case should be tried where the offense was committed, which in this case, was Pasig City. This interpretation was supported by the Ombudsman, who argued that the venue provision of RA 10660 was not self-executing and required the Supreme Court’s implementing rules to be effective.

The Supreme Court disagreed with the RTC and the Ombudsman. The Court emphasized that jurisdiction is conferred by law, and RA 10660 clearly vests jurisdiction in the RTC for certain graft cases while simultaneously specifying the venue. The phrase “subject to the rules promulgated by the Supreme Court” was not meant to suspend the effectivity of the venue provision. Instead, it acknowledges the Supreme Court’s power to issue procedural rules but does not make the statutory venue requirement contingent upon such issuance. The Court referenced Senate deliberations on RA 10660 to show the legislative intent behind the venue provision: to prevent public officials from exerting influence over local judges.

The Court clarified that Section 15(a), Rule 110 of the Revised Rules on Criminal Procedure, which the RTC relied upon, is explicitly “subject to existing laws.” Since RA 10660 is an existing law specifying venue, it takes precedence over the general venue rule. The Supreme Court stated:

SEC. 15. Place where action is to be instituted. —

(a)	Subject to existing laws, the criminal action shall be instituted and tried in the court of the municipality or territory where the offense was committed or where any of its essential ingredients occurred.

The Court highlighted that the RTC’s interpretation would render the legislative intent of RA 10660 nugatory. To wait for implementing rules would effectively suspend the operation of a substantive legal provision on venue, which is against established principles of statutory construction. The Supreme Court reiterated that procedural rules cannot override substantive law. Therefore, the RTC Pasig City acted with grave abuse of discretion in denying the Motion to Quash, as it lacked jurisdiction over the case due to improper venue as mandated by RA 10660.

Ultimately, the Supreme Court granted the petition, annulling the RTC Orders and ordering the dismissal of Criminal Case No. R-PSG-18-01280-CR. All actions taken by the RTC Pasig City in the case were declared null and void for lack of jurisdiction. This decision reinforces the principle that statutory venue provisions must be strictly followed, especially in cases involving public officials, to ensure fairness and impartiality in the administration of justice.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Alfredo J. Non, et al. v. Office of the Ombudsman, G.R No. 251177, September 08, 2020