Santiago vs Sandiganbayan

G.R. No. 128055, April 18, 2001

VITUG, J.

FACTS:

Sen. Santiago approved the application for legalization of the stay of aliens who arrived in the
Philippines in violation of E.O. No. 324 which prohibits the legalization of said disqualified aliens
knowing that said aliens are disqualified. Two other criminal cases were filed against Santiago.
Pursuant to this information, presiding Justice of the Sandiganbayan, issued a warrant of arrest
against Santiago. Santiago petitioned for provisional liberty since she was just recovering from a car
accident which was approved. In 1995, a motion was filed with the Sandiganbayan for the suspension
of Santiago, who was already a senator by then. The Sandiganbayan ordered the Senate President
(Maceda) to suspend Santiago from office for 90 days.

ISSUE:

Whether or not Sandiganbayan has the jurisdiction to suspend an incumbent public official
charged with the violation of RA 3019

HELD:

Yes. Sandiganbayan has the jurisdiction to suspend an incumbent public official charged with
the violation of RA 3019

Section 16 (3), Article VI of the Constitution which deals with the power of each House of
Congress to punish its Members for disorderly behavior is unavailing, as it appears to be quite distinct
from the suspension spoken of in Section 13 of RA 3019, which is not a penalty but a preliminary,
preventive measure, prescinding from the fact that the latter is not being imposed on petitioner for
misbehavior as a Member of the House of Representatives. The doctrine of separation of powers by
itself may not be deemed to have effectively excluded members of Congress from Republic Act No.
3019 nor from its sanctions. The maxim simply recognizes each of the three co-equal and
independent, albeit coordinate, branches of the government the Legislative, the Executive and the
Judiciary has exclusive prerogatives and cognizance within its own sphere of influence and effectively
prevents one branch from unduly intruding into the internal affairs of either branch.

Facts of the Case:

Members of Congress may also be suspended by the Sandiganbayan or by the Office of the
Ombudsman.