LACSON vs.

EXECUTIVE SECRETARY
G.R. No. 128096 January 20, 1999

1) For the SB to assume jurisdiction over the case, it is not enough that it be alleged in the
Information that the accused public officer “committed the crime in relation to his office”. The
Information must contain specific allegation of facts showing that the crime is “intimately
connected” with the office of the accused such as (1) that he committed the crime while in the
performance of his official functions; (2) that he had no personal motives and would not have
committed crime if not for his office; (3) that he used the powers of his office to commit the crime
or (4) that he could not have committed the crime if not for his office.

2) The use of the phrase in the Information “the accused committed the crime in relation to
his public office”, which is a mere conclusion of law, is not what determines the jurisdiction of the
Sandiganbayan. What is controlling is the specific factual allegations in the information that would
indicate the close intimacy between the discharge of the accused's official duties and the
commission of the offense charged. Thus, even if the phrase does not appear in the Information, the
SB may exercise jurisdiction if there are specific factual allegations showing close intimacy
between the discharge of the accused's official duties and the commission of the crime charged.

SANCHEZ vs. DEMETRIOU

G.R. Nos. 111771-77 November 9, 1993

1) The SB is without jurisdiction over the case because there is no allegation in the
information showing that that there is an "intimate connection" between the offense of rape with
homicide and the accused’s official functions as municipal mayor. It follows that the said crime,
being an ordinary offense, is triable by the regular courts and not the Sandiganbayan.