Facts:
The Senate and the House of Representatives conducted several inquiries on the proliferation of dangerous drugs syndicated at the New Bilibid Prison (NBP), inviting inmates who executed affidavits in support of their testimonies. These legislative inquiries led to the filing of three complaints with the Department of Justice against Senator Leila M. De Lima, et al.;
On February 17, 2017, three Information were filed against petitioner De Lima and several co-accused before the RTC of Muntinlupa City. One of the Information was raffled off to Branch 204, presided by respondent judge. This Information charging petitioner for violation of Section 5 in relation to Section (jj), Section 26(b), and Section 28 of Republic Act No. (RA) 9165.
On February 23, 2017, respondent judge issued an Order finding probable cause for the issuance of warrants of arrest against De Lima and her co-accused. Accordingly, the Warrant of Arrest which contained no recommendation for bail, was issued against petitioner.
On February 24, 2017, the PNP Investigation and Detection Group served the Warrant of Arrest on petitioner and the respondent judge issued an Order committing petitioner to the custody of the PNP Custodial Center.
On February 27, 2017, petitioner repaired to the Supreme Court via the present petition, praying for
annulling and setting aside the Warrant of Arrest of the Regional Trial Court – Branch 204, Muntinlupa City as the said court lacks jurisdiction over the petitioner;
Petitioner argues that, based on the allegations of the Information in the Criminal Case, the Sandiganbayan has the jurisdiction to try and hear the case against her. She posits that the Information charges her not with violation of RA 9165 but with Direct Bribery-a felony within the exclusive jurisdiction of the Sandiganbayan given her rank as the former Secretary of Justice with Salary Grade 31. For the petitioner, even assuming that the crime described in the Information is a violation of RA 9165, the Sandiganbayan still has the exclusive jurisdiction to try the case considering that the acts described in the Information were intimately related to her position as the Secretary of Justice. Some justices of this Court would even adopt the petitioner’s view, declaring that the Information charged against the petitioner is Direct Bribery.
Issue:
Whether Sandiganbayan not RTC has jurisdiction over the person of the petitioner?
Held:
No, The pertinent special law governing drug-related cases is RA 9165, which updated the rules provided in RA 6425, otherwise known as the Dangerous Drugs Act of 1972. A plain reading of RA 9165, as of RA 6425, will reveal that jurisdiction over drug-related cases is exclusively vested with the Regional Trial Court and no other. The designation of the RTC as the court with the exclusive jurisdiction over drug-related cases is apparent in the following provisions where it was expressly mentioned and recognized as the only court with the authority to hear drug-related cases. Notably, no other trial court was mentioned in RA 9165 as having the authority to take cognizance of drug-related cases. In this case, RA 9165 specifies the RTC as the court with the jurisdiction to “exclusively try and hear cases involving violations of [RA 9165).” This is an exception, couched in the special law on dangerous drugs, to the general rule under Section 4(b) of PD 1606, as amended by RA 10660. It is a canon of statutory construction that a special law prevails over a general law and the latter is to be considered as an exception to the general.
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