Cariaga vs.

People, 626 SCRA 231

Rationale: The Court may relax its rules when it involves criminal cases where it would deprive
a person of their liberty due to procedural errors. Rules of procedure must be viewed as tools
to facilitate the attainment of justice and should not prevent the Court from dispensing justice.

Facts:
 Cenita Cariaga, petitioner, who has a salary grade of 24, initiated this case to review the
decision of the CA of dismissing her case for lack of jurisdiction.
 Cariaga took advantage of her position as the municipal treasurer of Cabatuan, Isabela and was
charged with 3 counts of malversation of public funds in the RTC of Cabatuan and was also
charged with the three separate cases.
 When Cariaga submitted her Notice of Appeal to the CA, the CA dismissed her petition for lack
of Jurisdiction and said that it is the Sandiganbayan who has jurisdiction over her appeal for her
case.
 Following the case, RA 8249, provides that RTC has jurisdiction over cases against public officers
with salary grade below 27, and then it is Sandiganbayan who enjoys appellate jurisdiction for
these offenses. The petition was denied accordingly.
 Cariaga recognizes the procedural error made by her counsel and appeals to the court to relax
the rules to have the opportunity of affording her appeal and endorse her case to
Sandiganbayan. (WOW PRINCESS TREATMENT?)

Issue:

 W/N The Court can grant the petitioner’s appeal of relaxing procedural rules.

Held:

 PD 1606, as amended by RA 8249 provides that all cases involving public officials with a
salary grade lower than 27, Sandiganbayan is afforded jurisdiction. But since this case
involves a criminal liability where a person may be deprived of liberty just because of
procedural lapses, the Court granted the appeal to relax its Rules.
 Rules of procedure should be viewed as tools to attain justice. The inadequacy of Cariaga’s
former counsel and the trial court’s lapses almost deprived her of her liberty and property.