Alzaga vs. Sandiganbayan
Alzaga vs. Sandiganbayan
Alzaga vs. Sandiganbayan
YNARES-SANTIAGO, J.
FACTS
On October 7, 1999, four separate Informations for violation of Section 3(e) of Republic Act
(R.A.) No. 3019 were filed against petitioners Julian A. Alzaga, Meinrado Enrique A. Bello and
Manuel S. Satuito relative to alleged irregularities which attended the purchase of four lots in
Tanauan, Batangas, by the Armed Forces of the Philippines Retirement and Separation Benefits
System (AFP-RSBS).
Alzaga was the Head of the Legal Department of AFP-RSBS when one of the lots was purchased.
Bello was a Police Superintendent and he succeeded Alzaga as Head of the Legal Department. It
was during his tenure when the other three lots were purchased. Both were Vice Presidents of
AFP-RSBS. On the other hand, Satuito was the Chief of the Documentation and Assistant Vice
President of the AFP-RSBS.
Petitioners filed their respective Motions to Quash and/or Dismiss the informations alleging that
the Sandiganbayan has no jurisdiction over them and their alleged offenses because the AFP-
RSBS is a private entity created for the benefit of its members.
Sandiganbayan initially granted their motion to quash/or dismiss citing lack of jurisdiction, but
later reversed the decision, holding that AFP-RSBS is a government-owned or controlled
corporation thus subject to its jurisdiction.
ISSUE
RULING
“In People v. Sandiganbayan, where herein petitioners Alzaga and Satuito were respondents,
this Court has ruled that the character and operations of the AFP-RSBS are imbued with public interest
thus the same is a government entity and its funds are in the nature of public funds . In Ramiscal, Jr. v.
Sandiganbayan,16 we held that the AFP-RSBS is a government-owned and controlled corporation
under R.A. No. 9182, otherwise known as The Special Purpose Vehicle Act of 2002. These rulings
render unmeritorious petitioners’ assertion that the AFP-RSBS is a private entity.