The Supreme Court, in this case, affirmed the Sandiganbayan’s jurisdiction over cases involving municipal mayors charged with violating the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019), regardless of their actual salary. The determining factor is the salary grade attached to the position of municipal mayor, which, by law, is Grade 27 or higher, placing it under the Sandiganbayan’s exclusive jurisdiction. This ruling clarifies that it is the official’s position and its corresponding salary grade, rather than the actual salary received, that determines the Sandiganbayan’s authority to hear the case, ensuring consistent application of anti-graft laws across municipalities.

The Case of the Knockdown Boxes and the Denied Permits: A Mayor’s Brush with Graft Charges

This case revolves around Crescente Y. Llorente, Jr., then the municipal mayor of Sindangan, Zamboanga del Norte, who faced two separate criminal charges before the Sandiganbayan. The first, Criminal Case No. 19763, involved alleged violations of Section 3(e) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act, relating to the unlawful seizure of wooden boxes. The second, Criminal Case No. 22655, concerned alleged violations of Section 3(f) of the same Act, stemming from the refusal to issue a mayor’s permit to a local business. The central legal question was whether the Sandiganbayan retained jurisdiction over these cases, considering Llorente’s position as municipal mayor and the passage of Republic Act No. 7975, which amended the jurisdictional provisions of the Sandiganbayan.

Llorente argued that Republic Act No. 7975 had divested the Sandiganbayan of jurisdiction over cases involving municipal mayors whose salaries were less than that corresponding to Grade 27. He contended that his actual salary at the time did not meet this threshold, and therefore, the cases should be transferred to the Regional Trial Court. However, the Sandiganbayan denied his motions to dismiss or transfer the cases, leading Llorente to file petitions for certiorari with the Supreme Court, questioning the Sandiganbayan’s jurisdiction.

The Supreme Court consolidated the two cases and addressed the core issue of whether Republic Act No. 7975 indeed removed municipal mayors from the Sandiganbayan’s jurisdictional ambit. The Court emphasized that it is not the actual salary received by a public official that determines their salary grade, but rather the official’s grade that dictates their salary. The Court then made reference to Section 444 (d) of the Local Government Code, which states that “the municipal mayor shall receive a minimum monthly compensation corresponding to Salary Grade twenty-seven (27) as prescribed under Republic Act No. 6758 and the implementing guidelines issued pursuant thereto.”.

Furthermore, the Supreme Court cited its previous rulings in similar cases, such as Binay v. Sandiganbayan, reinforcing the principle that the **salary grade**, as defined by Republic Act No. 6758 (the Compensation and Position Classification Act of 1989) and the Index of Occupational Services, Position Titles and Salary Grades, is the determining factor for Sandiganbayan jurisdiction. In those rulings, the Court had explicitly said that:

“To determine whether the official is within the exclusive jurisdiction of the Sandiganbayan, therefore, reference should be made to Republic Act No. 6758 and the Index of Occupational Services, Position Titles and Salary Grades. An official’s grade is not a matter of proof, but a matter of law which the court must take judicial notice.”

Building on this principle, the Supreme Court held that, irrespective of the mayor’s actual compensation, the legal framework clearly designates the position of municipal mayor as belonging to Salary Grade 27. This classification places any violations of Republic Act No. 3019 committed by a municipal mayor squarely within the exclusive original jurisdiction of the Sandiganbayan.

The implications of this decision are significant. It clarifies that the Sandiganbayan’s jurisdiction over graft cases involving local officials is determined by the position’s established salary grade, ensuring consistent application of anti-graft laws. The decision upholds the legislative intent of Republic Act No. 7975 and Republic Act No. 8249, which redefined the Sandiganbayan’s jurisdiction, and prevents potential loopholes that could allow local officials to evade prosecution for graft and corruption based on arguments about their actual salary levels. This ruling ensures that public officials holding positions with a specified salary grade, like municipal mayors, are held accountable for their actions before the Sandiganbayan, regardless of their actual pay.

FAQs

What was the key issue in this case?	The central issue was whether the Sandiganbayan had jurisdiction over graft cases against a municipal mayor, given Republic Act No. 7975’s changes to jurisdictional requirements. The mayor argued his salary was below the threshold for Sandiganbayan jurisdiction.
What is Republic Act No. 3019?	Republic Act No. 3019 is the Anti-Graft and Corrupt Practices Act. It prohibits corrupt practices by public officers and prescribes penalties for violations.
What is Republic Act No. 7975?	Republic Act No. 7975 amended Presidential Decree No. 1606, redefining the Sandiganbayan’s jurisdiction. It focused on the salary grades of public officials to determine which court would have jurisdiction over their cases.
What is Salary Grade 27?	Salary Grade 27 refers to a specific compensation level in the Philippine government’s salary standardization system. It’s used to determine the jurisdiction of the Sandiganbayan over public officials.
How did the court determine jurisdiction in this case?	The court based its decision on the established salary grade for the position of municipal mayor, which is Grade 27. The court noted that jurisdiction isn’t about a specific individual’s pay but rather the position’s fixed classification under compensation laws.
What was the specific violation the mayor was accused of in Criminal Case No. 19763?	In Criminal Case No. 19763, the mayor was accused of violating Section 3(e) of R.A. 3019, which prohibits public officials from causing undue injury to any party or giving unwarranted benefits to any private party through manifest partiality, evident bad faith, or gross inexcusable negligence. This involved the seizure of wooden boxes.
What was the specific violation the mayor was accused of in Criminal Case No. 22655?	In Criminal Case No. 22655, the mayor was accused of violating Section 3(f) of R.A. 3019, which prohibits public officials from neglecting or refusing to act on official duties. This involved refusal to issue a mayor’s permit.
Does this ruling apply to all local government officials?	The ruling’s principles primarily affect officials whose positions have a specific salary grade under the Compensation and Position Classification Act of 1989 (R.A. 6758). Jurisdiction over these officials depends on their salary grade.

This case serves as a clear reminder that the Sandiganbayan’s jurisdiction over graft cases involving public officials is primarily determined by the salary grade attached to their position, rather than their actual salary. This ensures that public officials holding positions with a specified salary grade are held accountable for their actions before the Sandiganbayan, regardless of their actual pay, solidifying the fight against corruption in the Philippines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Crescente Y. Llorente, Jr. vs. Sandiganbayan, G.R. Nos. 122297-98, January 19, 2000