Antiporda v. Hon.

Garchitorena

Facts: Accused Antiporda Jr., and three others were charged with kidnapping
one Elmer Ramos. Because it was not clear whether or not the offense
committed was office-related, the Sandiganbayan ordered the prosecution to
amend the Information. The prosecution filed an Amended Information alleging
that one of the accused, Antporda, Jr., took advantage of his position as mayor of
Buguey, Cagayan to order the kidnapping of Elmer Ramos. Accused moved for a
reinvestigation of the case and for the deferment of the issuance of the warrants
of arrest but the Sandiganbayan denied his motion. Accused then moved to
quash the amended information for lack of jurisdiction of the Sandiganbayan over
the case, but the latter likewise denied the same.

Issue: Whether or not Sandiganbayan has the jurisdiction over the offense

Ruling: The Supreme Court held that accused are estopped from assailing the
jurisdiction of the Sandiganbayan over the case for in the motion for
reconsideration they had filed with the same court, they clearly stated that the
crime was work-connected. The Court also held that a reinvestigation need not
be conducted because the amendments to the information merely described the
public positions of the accused, and the purpose of a preliminary investigation (to
engender a well- grounded belief that a crime had been committed and accused
are probably guilty thereof) had already been achieved.

Layosa case: The voluntary appearance of the accused at the pre-suspension

hearing amounted to his submission to the court’s jurisdiction even if no warrant
of arrest has yet been issued.

De los Santos-Reyes case: The court said that the accused have no right to
invoke the processes of the court since they have not been placed in the custody
of the law or otherwise deprived of their liberty by reason or as a consequence of
the filling of the information. The court had no authority to act on the petition.
Reconciliation of the two cases: The only difference is that De los Santos-Reyes
case harped mainly on the warrant of arrest angle while the Layosa case dealt
more on issue of voluntary submission ruling.