COMELEC vs. Noynay

The Court held that the exclusive original jurisdiction of Regional Trial Courts over election offenses under Section 268 of the Omnibus Election Code remains intact despite the enactment of R.A. No. 7691, which expanded the jurisdiction of lower courts. The Court reasoned that the Omnibus Election Code is a special law, and its specific jurisdictional provision constitutes an exception to the general jurisdictional rules amended by R.A. No. 7691.

The Commission on Elections (COMELEC) authorized the filing of nine criminal cases against private respondents Diosdada Amor (a public school principal), Esbel Chua, and Ruben Magluyoan (public school teachers) for allegedly engaging in partisan political activity, a prohibited act under Section 261(i) of the Omnibus Election Code. The informations were filed with the Regional Trial Court (RTC) of Allen, Northern Samar.

• Nature of the Offense: Private respondents were charged with nine counts of violating Section 261(i) of the Omnibus Election Code for engaging in partisan political activity as public school officials and employees. The penalty prescribed under Section 264 is imprisonment of not less than one year but not more than six years, plus disqualification from public office and deprivation of suffrage.
• RTC's Jurisdictional Ruling: The RTC judge, acting motu proprio, ruled that pursuant to Section 32 of B.P. Blg. 129, as amended by R.A. No. 7691, the RTC lacked jurisdiction because the maximum imposable penalty did not exceed six years. He ordered the cases withdrawn and refiled in the appropriate Municipal Trial Court.
• COMELEC's Position: The COMELEC argued that Section 268 of the Omnibus Election Code vested exclusive original jurisdiction over such election offenses in the RTC, and that this special provision was not repealed by the general jurisdictional amendments in R.A. No. 7691.

• Petitioner COMELEC maintained that the Regional Trial Court has exclusive original jurisdiction to try and decide election offenses under Section 268 of the Omnibus Election Code.
• It argued that R.A. No. 7691, which expanded the jurisdiction of lower courts, did not impliedly repeal the special jurisdictional provision of the Omnibus Election Code.
• It invoked the Court's ruling in Naldoza v. Lavilles, Jr., which held that RTCs retain jurisdiction over election offenses as an exception to the general jurisdictional rules.

• Private respondents countered that R.A. No. 7691 expressly provides that all laws inconsistent with its provisions are deemed repealed or modified.
• They argued that since the election offense charged is punishable with imprisonment of not more than six years, exclusive original jurisdiction now lies with the Municipal Trial Court under the expanded jurisdiction granted by R.A. No. 7691.

• Procedural Issues: N/A
• Substantive Issues:
  • Whether R.A. No. 7691 divested the Regional Trial Courts of jurisdiction over election offenses punishable by imprisonment not exceeding six years.
  • Whether the special jurisdictional provision of Section 268 of the Omnibus Election Code prevails over the general jurisdictional amendments introduced by R.A. No. 7691.

• Procedural: N/A
• Substantive: The Court ruled in favor of the COMELEC. It held that the opening sentence of Section 32 of B.P. Blg. 129 (as amended by R.A. No. 7691) expressly excepts from the lower courts' jurisdiction cases falling within the exclusive original jurisdiction of the RTC and the Sandiganbayan. Section 268 of the Omnibus Election Code is a special law that places election offenses within the RTC's exclusive original jurisdiction. R.A. No. 7691, being a general amendatory law, did not repeal this special provision. The Court emphasized that Congress did not intend for R.A. No. 7691 to override special jurisdictional statutes.

• Special Law Prevails Over General Law (Lex Specialis Derogat Generali) — A special law (the Omnibus Election Code) providing for the specific jurisdiction of courts over a particular class of cases (election offenses) is not repealed or modified by a later general law (R.A. No. 7691) that amends general jurisdictional statutes. The special law remains an exception to the general law.

• "R.A. No. 7691 can by no means be considered as a special law on jurisdiction; it is merely an amendatory law intended to amend specific sections of the Judiciary Reorganization Act of 1980. Hence, R.A. No. 7691 does not have the effect of repealing laws vesting upon Regional Trial Courts or the Sandiganbayan exclusive original jurisdiction to hear and decide the cases therein specified." — This passage clarifies the nature of R.A. No. 7691 and its limited effect on pre-existing special jurisdictional laws.

• Morales v. Court of Appeals, G.R. No. 126623, December 12, 1997 — Cited as controlling authority. The Court applied its ruling in Morales that the exception clause in Section 32 of B.P. Blg. 129 preserves the exclusive jurisdiction of higher courts over cases specifically designated by other laws, regardless of the prescribed penalty.
• Naldoza v. Lavilles, Jr., A.M. No. MTJ-94-1009, March 5, 1996 (254 SCRA 286) — Cited for its holding that the RTC has exclusive original jurisdiction over election offenses under the Omnibus Election Code, and that this jurisdiction is not affected by the expanded jurisdiction of lower courts.

• Section 268, Omnibus Election Code (B.P. Blg. 881) — Provides that the Regional Trial Court shall have exclusive original jurisdiction to try and decide any criminal action for violation of the Code, except those relating to failure to register or vote. This was the controlling special law.
• Section 32, B.P. Blg. 129, as amended by Section 2, R.A. No. 7691 — Grants lower courts exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six years, but contains an opening clause excepting cases within the exclusive original jurisdiction of the RTC and the Sandiganbayan.

Chief Justice Andres R. Narvasa, Justices Florenz D. Regalado, Flerida Ruth P. Romero, Jose C. Bellosillo, Jose A.R. Melo, Reynato S. Puno, Vitug, Santiago M. Kapunan, Jose C. Mendoza, Artemio V. Panganiban, Leonardo A. Martinez, and Consuelo Ynares-Santiago.

N/A — The decision was unanimous.