Bartolome v. People, (1986); G.R. No. L-64548 and L-64559

Crim Pro- Jurisdiction

Facts:

Accused Rolando Bartolome was the Senior Labor Regulation Officer and Chief of the Labor Regulations Section of the Ministry of Labor, while his co-accused Elino Coronel was a Labor Regulation Officer of the same office. On January 12, 1977, Bartolome and Coronel falsified Bartolome's CS Personal Data Sheet making it appear that Bartolome had taken the Career Service Examination on May 2, 1976 with a rating of 73.35% in Manila. The two also made it appear in the same document that Bartolome was a 4th year AB student at the Far Eastern University. They were then charged with the crime of Falsification of Official Document in the Sandiganbayan which later found them guilty of the offense charged against them. Bartolome and Coronel, however, claimed that the Sandiganbayan has no jurisdiction over their case.

Issue: Whether or not the Sandiganbayan has jurisdiction over this case of falsification of an official document allegedly committed by public officers.

Held: No. The Supreme Court held that it was not shown that the alleged falsification was committed by the accused as a consequence of and while they were discharging official functions. The information filed against the accused did not allege that "there was an intimate connection between the discharge of official duties and the commission of the offense". The Court further pointed out that "falsification of an official document may be committed not only by public officers and employees but even by private persons only" and that "public office is not an essential ingredient of the offense such that the offense cannot exist without the office".