G.R. Nos.

118013-14 October 11, 1995

PEOPLE OF THE PHILIPPINES, petitioner,

vs.
HON. DEMOSTHENES L. MAGALLANES, as Presiding Judge of the Regional Trial Court

DAVIDE, JR., J.:

DOCTRINE

the jurisdiction of a court is determined by the law in force at the time of the commencement of the
action.

FACTS:
Two informations for kidnapping for ransom with murder were filed in the Regional Trial Court
of Bacolod City against fourteen persons, five of whom are members of the Philippine National Police.
The two cases was consolidated.
While the trial was on going, the prosecution file a motion for the transmittal of the case to the
Sandiganbayan on the ground that the trial court has no jurisdiction over the cases because the offense
charged were committed in relation to the office of the accused PNP officers.

ISSUE:
Whether or not the crimes charged falls under the jurisdiction of the Sandiganbayan.

HELD:
No, the case is no longer cognizable by the Sandiganbayan.
Ordinarily, jurisdiction once acquired is not affected by subsequent legislative enactment placing
jurisdiction in another tribunal. It remains with the court until the case is finally terminated. Hence, the
Sandiganbayan or the courts, as the case may be, cannot be divested of jurisdiction over cases filed
before them by reason of R.A. No. 7975. They retain their jurisdiction until the end of the litigation.
In the instant case, the Sandiganbayan has not yet acquired jurisdiction over the subject criminal
cases, as the informations were filed not before it but before the Regional Trial Court. Even if we labor
under the foregoing assumption that the informations in the subject cases do charge the respondent PNP
officers with offenses committed in relation to their office so that jurisdiction thereof would fall under
the Sandiganbayan, and assuming further that the informations had already been filed with the said
tribunal but hearing thereon has not begun yet, the Sandiganbayan can no longer proceed to hear the
cases in view of the express provision of Section 7 of R.A. No. 7975. That section provides that upon
the effectivity of the Act, all criminal cases in which trial has not yet begun in the Sandiganbayan shall
be referred to the proper courts. Hence, cases which were previously cognizable by the Sandiganbayan
under P.D. No. 1606, as amended, but are already under the jurisdiction of the courts by virtue of the
amendment introduced by R.A. No. 7975, shall be referred to the latter courts if hearing thereon has not
yet been commenced in the Sandiganbayan.
It would, therefore, be a futile exercise to transfer the cases to the Sandiganbayan because the
same would anyway be transferred again to the Regional Trial Court pursuant to Section 7 of the new
law in relation to Section 2 thereof.