Antiporda vs. Garchitorena

Antiporda vs. Garchitorena

G.R. No. L-133289, 321 SCRA 551, December 23, 1999

FACTS: Petitioners were charged with the crime of kidnapping one Elmer Ramos filed before the Sandiganbayan without claiming that one of the accused is a public officer who took advantage of his position. The information was amended to effectively describe the offense charged herein and for the court to effectively exercise its jurisdiction over the same by stating that Antiporda took advantage of his position. Accused filed a motion for new preliminary investigation and to hold in abeyance and/or recall warrant of arrest issued. The same was denied. The accused subsequently filed a motion to quash the amended information for lack of jurisdiction over the offense charged because of the amended information. This was denied as well as the MR on the same. Hence, this petition before the Supreme Court. ISSUE: Whether the Sandiganbayan has jurisdiction over the subject matter. RULING: YES. They are estopped from assailing the jurisdiction of the Sandiganbayan. The original Information filed with the Sandiganbayan did not mention that the offense committed by the accused is office-related. It was only after the same was filed that the prosecution belatedly remembered that a jurisdictional fact was omitted therein. However, we hold that the petitioners are estopped from assailing the jurisdiction of the Sandiganbayan for in the supplemental arguments to motion for reconsideration and/or reinvestigation dated June 10, 1997 filed with the same court, it was they who "challenged the jurisdiction of the Regional Trial Court over the case and clearly stated in their Motion for Reconsideration that the said crime is work connected. Jurisdiction is the power with which courts are invested for administering justice, that is, for hearing and deciding cases. In order for the court to have authority to dispose of the case on the merits, it must acquire jurisdiction over the subject matter and the parties. In the case of Arula vs. Espino it was quite clear that all three requisites, i.e., jurisdiction over the offense, territory and person, must concur before a court can acquire jurisdiction to try a case. It is undisputed that the Sandiganbayan had territorial jurisdiction over the case. And we are in accord with the petitioners when they contended that when they filed a motion to quash it was tantamount to a voluntary submission to the Court's authority.