Bryan Subido Jr. and Rena Parina were charged with unlawfully detaining James J. Laxamana for 43 days despite knowing a deportation order against him was not yet final. Subido Jr. and Parina claimed the Sandiganbayan no longer had jurisdiction over the offense or their persons due to an amendment to the law. However, the Court held that under the amended law, jurisdiction is determined based on the positions held at the time the crime was committed, not at the time of filing the charges. Since Subido Jr. held a position higher than Grade 27 when the crime occurred, the Sandiganbayan had jurisdiction over the case.
Bryan Subido Jr. and Rena Parina were charged with unlawfully detaining James J. Laxamana for 43 days despite knowing a deportation order against him was not yet final. Subido Jr. and Parina claimed the Sandiganbayan no longer had jurisdiction over the offense or their persons due to an amendment to the law. However, the Court held that under the amended law, jurisdiction is determined based on the positions held at the time the crime was committed, not at the time of filing the charges. Since Subido Jr. held a position higher than Grade 27 when the crime occurred, the Sandiganbayan had jurisdiction over the case.
Bryan Subido Jr. and Rena Parina were charged with unlawfully detaining James J. Laxamana for 43 days despite knowing a deportation order against him was not yet final. Subido Jr. and Parina claimed the Sandiganbayan no longer had jurisdiction over the offense or their persons due to an amendment to the law. However, the Court held that under the amended law, jurisdiction is determined based on the positions held at the time the crime was committed, not at the time of filing the charges. Since Subido Jr. held a position higher than Grade 27 when the crime occurred, the Sandiganbayan had jurisdiction over the case.
and Rena Parina vs The Honorable Sandigan-Bayan and
the People of the Philippines G.R. No. 122641, 20 January 1997 Facts Then Commissioner of the Bureau of Immiration an! "e#ortation $BI"% Bayani &u'i!o, Jr.,an! BI" &#e(ia) *ent Rene +arina, ,hi)e in the #erforman(e of their offi(ia) fun(tions, (ause! the issuan(e an! im#)ementation of a ,arrant of arrest !ate! June 2-, 1992 aainst James J. .a/simu/, !es#ite /no,in fu))y ,e)) that the BI" "e(ision !ate! June 6, 1991, re0uirin .a/simu/1s !e#ortation has not as yet 'e(ome fina) an! e2e(utory (onsi!erin the #en!en(y of a .otion for Re(onsi!eration, resu)tin in the !etention of the )atter for a #erio! of forty3three $44% !ays an!, thus, (ausin him un!ue in5ury. 6ne year, ten months an! t,enty3one !ays after the a))ee! (rime ,as (ommitte!, +.". No. 1606 ,as amen!e! 'y R.*. No. 797-. *t the time of the fi)in of the information, &u'i!o ,as a)rea!y a #ri7ate (iti8en an! +arina9s #osition ,as )o,er than Gra!e :27; thus #rom#tin them to 'e)ie7e that theirs is not one of those (ases ,hi(h the &an!ian'ayan sha)) ha7e 5uris!i(tion. Issue *re the #etitioners (orre(t in assertin that un!er the )a, amen!in +.". No. 1606, the &an!ian'ayan has no 5uris!i(tion o7er the offense (hare! an! their #ersons< Held No. The #etitioners o7er)oo/ the fa(t that for #ur#oses of =4 of +.". No. 1606, as amen!e!, the re(/onin #oint is the time of the commission of the crime. This is #)ain from the )ast ()ause of the o#enin senten(e of #arara#h $a%, =4 of +.". No. 1606, as further amen!e! 'y R.*. No. 797-. +arina9s ()aim that he he)! a #osition ,ith a sa)ary ra!e of )ess than >27> at the time of the (ommission of the a))ee! ar'itrary !etention an! is of no moment. ?e is #rose(ute! as a (o3(ons#irator of #etitioner &u'i!o, a #rin(i#a) a((use!, ,ho he)! a #osition hiher than ra!e >27.>
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