DOCTRINE:

If the facts set out in the complaint or information are sufficient to show the court in which the complaint or information is presented has jurisdiction, then the court has jurisdiction
It is well established that the jurisdiction of a court to try a criminal case is determined by the law in force at the time of the institution of the action. Once the court acquires jurisdiction over a
controversy, it shall continue to exercise such jurisdiction until the final determination of the case and it is not affected by subsequent legislation vesting jurisdiction over such proceedings
in another tribunal..

TITLE FACTS ISSUE(S) RULING(S)

Alarilla (petitioner) Whether or not Sandiganbayan

v.  The Office of the Ombudsman, through the Prosecutor, filed has jurisdiction over the case YES. SB HAS JURISDICTION.
an information with the Sandiganbayan charging petitioner
Sandiganbayan, In criminal cases, the court’s jurisdiction is initially
Alarilla with the crime of grave threats. Under RPC
determined by the FACTS ALLEGED in the
 A second information was filed charging petitioner Alarilla of complaint or information.
G.R. No. 136806, 22
August 2000 having violated section 3 (e) of RA 3019: special law Addtl chika: If the FACTS ALLEGED in the complaint or
The resolution of a demurrer to information are sufficient to show the court in
Causing any undue injury to any party or giving any party
evidence should be left to the which the complaint or information is presented has
unwarranted benefits, advantage or preference in the discharge exercise of sound judicial jurisdiction, then the court has jurisdiction.
of his official administrative or judicial functions through manifest discretion. If the court denies a
partiality… demurrer, certiorari is not the In the case at bar, the COMPLAINT is sufficient in
remedy UNLESS ONLY if it can
alleging the office-related nature of the crime.
be shown that there was GRAVE
ABUSE OF DISCRETION.
TOPIC: There was none in the denial of
 SO TWO CRIMES: Alarilla’s demurrer. In the complaint, Alarilla’s attendance in the public
Jurisdiction is conferred
by law 1. Grave threats hearing is in his capacity as mayor because the
2. Violation of RA 3019 hearing was about the community’s health and
sanitation problem.
 Sandiganbayan required the amendment of the grave
threats information to indicate the "office-related" character of It was there where his anger causing him to point
a gun at the complainant EMANATED from his
the crime.
official duties—because the complainant criticized
 Case involving RA 3019 was dismissed him in his official duties and pointing the gun was
his response.
GER WORDS/  The Sandiganbayan admitted the amended information:
KEYWORD(S):

“Accused, a public officer, being a municipal mayor, committed

grave threats by threatening with a gun one Simeon Legaspi NO, THE DISMISSAL OF THE RA3019
during a public hearing after Legaspi rendered a privilege VIOLATION CASE DOES NOT WARRANT THE
speech critical of the abuses and excesses of the DISMISSAL OF THE GRAVE THREATS CASE
administration of Alarilla.
[This time, the grave threats information now alleges its The reason?
office-related nature]
The RA3019 violation REQUIRES said offense of
causing injury and giving preference TO BE DONE
 Petitioner Alarilla filed a MR praying that the court IN THE COURSE of his official duties.
reconsider its admission of the amended information.
The offense in the RA3019 information was done
Because Alarilla claimed that the both crimes charged arose AFTER THE PUBLIC HEARING. That’s why it was
out of the same incident; that considering that the RA 3019 dismissed.
violation case had already been dismissed by the court on
the ground that it had no jurisdiction over the same since the But as for the Grave Threats information, all the
crime charged was not "office-related," the same ruling should law requires for the crime to be within the jurisdiction
apply to the grave threats case. of Sandiganbayan is the felony was committed "IN
RELATION TO HIS OFFICE"—which we’ve
Since the 2 cases arose from the same incident, the grave threat established as such because pointing the gun was
 case should be dismissed, since the violation of RA 3019 was his response to the complainant’s criticism of his
dismissed due to lack of jurisdiction of the Sandiganbayan since office.
the case is not “office-related”.

Sandiganbayan's ruling:
SANDIGANBAYAN’S JURISDICTION OVER THE
The crime charged was "office-related," hence, within the CASE AT BAR IS CONFERRED BY LAW
jurisdiction of this court.
The amended information was filed with the
Sandiganbayan and admitted in 1997.

The governing law, PD 1606 EXPRESSLY

PROVIDES that crimes charged against public
officers in relation to his office SHALL BE
UNDER THE JURISDICTION OF THE
SANDIGANBAYAN.

thus, based on the allegations in the

information, the Sandiganbayan correctly
assumed jurisdiction over the case.