Adaza v. Sandiganbayan, G.R. No.

154886, July 28, 2005

Carpio-Morales, J.

Facts:
In 1996, the Department of Public Works and Highways (DPWH) in
the 1st District of Zamboanga del Norte awarded a construction contract for a
school building to the Parents and Teachers Association (PTA) of Manawan
National High School (MNHS) in Manawan, Jose Dalman, Zamboanga del
Norte. The petitioner, who was the municipal mayor at the time, was involved
in the project. Although the project was completed in June 1997, the PTA did
not receive the last installment payment of P20,847.17. Upon verification, it
was revealed that the check had been released to the petitioner. The PTA
President discovered discrepancies in the signatures on the disbursement
voucher and check. Allegations surfaced that the petitioner had obtained the
check by forging signatures. The case was forwarded to the Office of the
Ombudsman, and after a preliminary investigation, probable cause was found.

The petitioner was charged with falsification of public documents

before the Sandiganbayan. During the trial, the petitioner was found guilty in
the first case but acquitted in the second case due to insufficient evidence. The
petitioner filed a Motion for Reconsideration, which was denied, leading to
the present petition for certiorari, claiming that the Sandiganbayan committed
grave abuse of discretion.

Issue:
Whether or not Sandiganbayan has jurisdiction over a public official's
offense of falsification of public documents in connection with his office.

Ruling:
Yes. The Sandiganbayan has jurisdiction over a public official's offense
of falsification of public documents in connection with his office. The
Sandiganbayan ruled that to fall under its exclusive original jurisdiction, an
offense must violate specific laws, involve a public official or employee, and
be related to the office. In this context, the Sandiganbayan asserted its
authority to handle the case concerning the falsification of public documents
by a public official in connection with his office. This decision was grounded
in the legal provisions defining the Sandiganbayan's jurisdiction as a
specialized court with exclusive original jurisdiction over cases implicating
certain laws, including the Anti-Graft and Corrupt Practices Act, particularly
when government officials hold specified positions. For the Sandiganbayan to
have exclusive jurisdiction, the offense must be committed by a public official
in one of the designated roles and be linked to the office.

Here, the petitioner, a public official during the offense, engaged in

falsification of public documents directly related to his duties as municipal
mayor, thereby affirming the Sandiganbayan's jurisdiction over the case.