CARIAGA V.

PEOPLE
G.R. No. 180010 July 30, 2010

FACTS:
Petitioner, a municipal treasurer with a Salary Grade of 24, was charged before the RTC with
three counts of malversation of public funds as defined under Art. 217 of the RPC. RTC
convicted petitioner in the three cases. Petitioner filed a Notice of Appeal, stating that he
intended to appeal the trial court’s decision to the Court of Appeals. The CA dismissed
petitioner’s appeal for lack of jurisdiction, holding that it is the Sandiganbayan which has
exclusive appellate jurisdiction over the case. Petitioner’s Motion for Reconsideration was also
denied. Hence, the present petition for review.

ISSUES:
1) WoN the Sandiganbayan has jurisdiction over the case
2) WoN the appeal of the petitioner wrongfully directed to the CA be dismissed outright or be
endorsed and transmitted to the Sandiganbayan where the appeal shall then proceed in
due course.

HELD:
1) Yes. The appellate jurisdiction in this case clearly pertains to the Sandiganbayan. Section 4
of PD 1606, as amended by RA 8249 provides, “The Sandiganbayan shall exercise exclusive
original jurisdiction in all cases… where none of the accused are occupying positions
corresponding to Salary Grade ‘27’ or higher…”

2) Since the appeal involves criminal cases, and the possibility of a person being deprived of
liberty due to a procedural lapse militates against the Court’s dispensation of justice, the
Court grants petitioner’s plea for a relaxation of the Rules.
 For rules of procedure must be viewed as tools to facilitate the attainment of justice, such
that any rigid and strict application thereof which results in technicalities tending to
frustrate substantial justice must always be avoided.
 The records of the cases were forwarded to the Sandiganbayan for proper disposition.