Case No.: G.R. NO.

152398
Case Title: Edgar Crisostomo v. Sandiganbayan
Date: April 14, 2005

Summary of Facts:
SPO1 Edgar Crisostomo appealed through certiorari against Sandiganbayan Resolutions denying his motion
for reconsideration. He was initially found guilty of murdering Renato Suba, a detention prisoner, on February
14, 1989, at the Solano Municipal Jail, where Crisostomo served as a police officer and jail guard.

Issues:
1. Jurisdiction of the Sandiganbayan
2. Guilt of Crisostomo

Ruling and Decision:

Jurisdiction of the Sandiganbayan:

The Sandiganbayan has jurisdiction over the case pursuant to Section 4(a)(2) of PD 1606, as amended by PD
1861, which grants it exclusive original jurisdiction over "Other offenses or felonies committed by public officers
and employees in relation to their office." As Crisostomo was a jail guard accused of murdering a detention
prisoner under his custody, the offense fell within the Sandiganbayan's jurisdiction.

Guilt of Crisostomo:
The prosecution failed to establish Crisostomo's guilt beyond reasonable doubt. Despite circumstantial
evidence and discrepancies in records, there was no direct evidence linking Crisostomo to the murder. The
autopsy reports ruled out suicide, indicating foul play, but did not conclusively implicate Crisostomo in the
conspiracy. Thus, Crisostomo was acquitted due to insufficient evidence.

Highlight Doctrine:

Doctrine of Prima Facie Case:

The Sandiganbayan relied on the doctrine of prima facie case in evaluating the evidence against Crisostomo.
A prima facie case is one where the prosecution has presented sufficient evidence to prove the elements of the
crime charged, thereby establishing a rebuttable presumption of guilt. In this case, the Sandiganbayan found
that the prosecution had presented enough evidence to establish a prima facie case against Crisostomo,
shifting the burden of proof to the defense to rebut this presumption. However, the defense successfully
argued that the evidence presented was not sufficient to overcome the presumption of innocence, leading to
Crisostomo's acquittal.

Rules, Laws, and Codes:

- Revised Rules of Civil Procedure, Rule 65: Governs appeals by certiorari.
- Presidential Decree No. 1606, as amended by Presidential Decree No. 1861: Grants Sandiganbayan
exclusive original jurisdiction over offenses committed by public officers and employees in relation to their
office.
- Doctrine of Prima Facie Case: Established legal principle guiding the evaluation of evidence in criminal
cases, shifting the burden of proof to the defense once the prosecution establishes a prima facie case.

The cause of the accusation is relevant in this case as it forms the basis for the charges against SPO1 Edgar
Crisostomo. Crisostomo was accused of murdering Renato Suba, a detention prisoner under his custody at the
Solano Municipal Jail. Understanding the cause of the accusation helps in assessing the motive behind the
alleged crime and provides context for evaluating the evidence presented during the trial.

In this case, the prosecution alleged that Crisostomo conspired with six inmates to kill Renato Suba. The cause
of the accusation, therefore, revolves around the motive attributed to Crisostomo, which was purportedly to
avenge an attack on another individual, Diosdado Lacangan, by Renato Suba. This motive is crucial in
establishing the prosecution's theory of the case and demonstrating why Crisostomo would have participated
in the conspiracy to murder Renato.

Furthermore, the cause of the accusation is relevant in determining the elements of the crime charged and
assessing the credibility of the evidence presented by both the prosecution and the defense. It helps in
understanding the circumstances surrounding the alleged offense and evaluating whether there is sufficient
evidence to prove Crisostomo's guilt beyond a reasonable doubt.

Overall, the cause of the accusation provides essential context for understanding the allegations against
Crisostomo and plays a significant role in the evaluation of the case by both the prosecution and the defense.