Bartolome v People

Facts:
Rolando Bartolome and Elino Coronel are both oIIicers oI Ministry oI Labor, NCR, Manila. They
conspired to IalsiIy the Civil Service Personal Data Sheet oI Bartolome making it appear that he
passed the career service exam and that he was a 4th year AB student oI FEU. Ricardo
Buenviaje, Tanodbayan Special Prosecutor Iiled a case at the Sandiganbayan accusing them oI
the crime oI FalsiIication oI OIIicial Document.
Sandiganbayan convicted them. Petitioners now question the validity oI Sandigabayans ruling.
Issue:
Whether or not Sandiganbayan has jurisdiction over petitioners case
SC Ruling:
Proceedings in Sandiganbayan are null and void ab initio. Under Section 4 oI PD 160,
Sandiganbayan shall have jurisdiction over:
1.Violations oI Anti-GraIt and Corrupt Practices and RA 1379
2.Crimes committed by public oIIicers and employees, including those in (Govt Owned or
Controlled Corporations) GOCCs, embraced in Title VII oI the RPC
3.Other crimes or oIIenses committed by public oIIicers or employees including those
employed in GOCCS in relation to their oIIice.
Nowhere does the act oI IalsiIication belong to the abovementioned cases where the
Sandiganbayan have jurisdiction. FalsiIication oI Public Document is embraced in Title IV oI the
RPC. Perhaps the nearest reason Ior Sandiganbayans taking cognizance oI the case is scenario
3 in the above enumeration. However, it does not appear that the oIIicial positions oI Bartolome
and Coronel were connected to the oIIense they committed. They did not need to be government
employees to IalsiIy a public document. In the light oI the Montilla case, it was upheld that when
public oIIice is not an essential ingredient oI the oIIense such that the oIIense cant exist without
the oIIice, it does not Iall under Sandiganbayans jurisdiction.
over PCGG cases.
R,94

There is no dispute that PJI is now under sequestration by the PCGG and that civil case no. 0035
was Iiled in Sandiganbayan wherenin the PJI is listed as among the corporations involved in the
unexplained wealth wealth case against Marcos. Records also show that Olaguer was acting in
behalI oI the PCGG and under Section 2 oI EO !$, the Sangiganbyana has exclusive and original
jurisdiction over all cases regarding the unexplained wealth oI Marcos. The decision oI the
Sandiganbayan is subject to review on certiorari exclusively by the Supreme Court.
In the exercise oI its Iunctions, the PCGG is a co-equal body with the RTC and co-equal bodies
have no power to control the other.