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Doctrine:

The rule is that in order to ascertain whether a court has jurisdiction or not, the provisions of the law
should be inquired into. Furthermore, the jurisdiction of the court must appear clearly from the
statute law or it will not be held to exist. It cannot be presumed or implied. For this purpose in criminal
cases, the jurisdiction of the court is determined by the law at the time of the commencement of the
action.

Facts

 Jerry was allegedly shot and killed by the mayor’s son. His body was then brought to the medical
clinic of the wife of the mayor, a municipal health officer. She also conducted an autopsy.
 Because of what happened, the widow of Jerry filed a complaint with the Ombudsman against
the mayor and the wife for tampering with the cadaver of Jerry.
 The Ombudsman then recommended the filing of an information for obstruction of justice
against them with the Sandiganbayan.
 The spouses Sollers argued that the Sandiganbayan had no jurisdiction over the offenses
charged, but Sandiganbayan ruled that it has. Since the mayor occupies a position at Grade Level
27 and his co-accused wife occupies a position at Grade level 24, the offense of the latter
elevates the case to the Sandigabayan because the mayor is co-accused with the lower-ranking
officer.
 Now, the spouses posit that Petitioners assert that in the subject criminal cases, the Informations
do not contain facts showing that they committed the acts charged in relation to their office.
 The People of the Philippines contend that the fact that the informations do not allege that the
acts charged were committed by the mayor while he was in the performance of his official
functions or duties is not a fatal defect because his acts which are allegedly in violation of his
duties as municipal mayor could necessarily be deduced from the informations.

Issue

 W/N Sandiganbayan has jurisdiction to try and hear the case.

Ruling

 No. The Sandiganbayan has no jurisdiction to try and hear the case.
 The rule is that in order to ascertain whether a court has jurisdiction or not, the provisions of the
law should be inquired into. Furthermore, the jurisdiction of the court must appear clearly
from the statute law or it will not be held to exist. It cannot be presumed or implied. For this
purpose in criminal cases, the jurisdiction of the court is determined by the law at the time of
the commencement of the action.
 In this case, the Sandiganbayan had no jurisdiction because there is a failure to show in the
information that the charges were intimately connected with the discharge of the official
functions of the accused mayor. Hence, the offenses charged in the criminal cases against the
spouses fall within the jurisdiction of the Regional Trial Court.

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