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JurisprudenceG.R. Nos. 205963-64 -

AMANDO A. INOCENTES, VS. PEOPLE OF THE PHILIPPINES, HON. ROLAND B. JURADO, IN HIS CAPACITY AS CHAIRPERSON, SANDIGANBAYAN, FIFTH DIVISION, HON. CONCHITA CARPIO MORALES, IN HER CAPACITY AS OMBUDSMAN, AS COMPLAINANT; AND HON. FRANCIS H. JARDELEZA, OFFICE OF THE SOLICITOR GENERAL (OSG), IN ITS CAPACITY

Cited Laws

RA 723RA 31,RA 187,RA 301,RA 3019RA 3019,RA 188,RA 8249,RA 367RA 70RA 6770,
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TL;DR — Ruling

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

Decision

Ruling

Accordingly, the informations filed against Inocentes in this case are valid because they adequately provide the material allegations to apprise him of the nature and cause of the charge. On the issue on jurisdiction, it is of no moment that Inocentes does not occupy a position with a salary grade of 27 since he was the branch manager of the GSIS' field office in Tarlac City, a government-owned or -controlled corporation, at the time of the commission of the offense, which position falls within the coverage of the Sandiganbayan's jurisdiction. The applicable law provides that 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 Sandiganbayan. [18] We have clarified the provision of law defining the jurisdiction of the Sandiganbayan by explaining that the 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. [19] 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. [20] In this category, it is the position held, not the salary grade, which determines the jurisdiction of the Sandiganbayan. [21] Furthermore, as the Sandiganbayan correctly held, even low-level management positions fall under the jurisdiction of the Sandiganbayan. We settled this point in Lazarte v. Sandiganbayan [22] and Geduspan v. People [23] . Based on the foregoing, we find that the Sandiganbayan was correct in denying Inocentes' motion to quash; hence, there was no grave abuse in the exercise of its discretion regarding this matter. A redetermination of a judicial finding of probable cause is futile when the accused voluntarily surrenders to the jurisdiction of the court. In the present case, the Office of the Ombudsman and the Sandiganbayan separately found that probable cause exists to indict and issue a warrant of arrest against Inocentes. However, what Inocentes brings before this Court right now is only the finding of the Sandiganbayan of probable cause for the issuance of a warrant of arrest. Under our jurisdiction, any person may avail of this remedy since it is well-established in jurisprudence that the court may, in the protection of one's fundamental rights, dismiss the case if, upon a personal assessment of evidence, it finds that the evidence does not establish probable cause. [24] In People v. Castillo , [25] we discussed the two kinds of determination of probable cause, thus: There are two kinds of determination of probable cause: executive and judicial. The executive determination of probable cause is one made during preliminary investigation. It is a function that properly pertains to the public prosecutor who is given a broad discretion to deter