Nuñez vs. Sandiganbayan PJA vs. Prado

Nuez vs.
Sandiganbayan
111 SCRA 433 (1982)
Facts:
Rufino Nuez was accused before the Sandiganbayan of estafa through falsification of public and
commercial documents committed in connivance with his other co-accused, all public officials, in several
cases. The informations were filed respectively on February 21 and March 26, 1979. Thereafter, on May
15 of that year, upon being arraigned, he filed a motion to quash on constitutional and jurisdictional grounds.
A week later, respondent Court denied such motion. There was a motion for reconsideration filed the next
day but it was denied. Hence this petition for certiorari and prohibition. It is the claim of petitioner that
Presidential Decree No. 1486, as amended, creating Sandiganbayan is violative of the due process, equal
protection, and ex post facto clauses of the Constitution.
Issue: Whether or not the trial of the accused by the Sandiganbayan is violative of the the equal protection
clause in light of the difference of the procedures as compared to regular courts.
Ruling:
No. The trial of the accused by the Sandiganbayan is not violative of the equal protection clause in
light of the difference of the procedures as compared to regular courts. That is hardly convincing,
considering that the classification satisfies the test announced by this Court through Justice Laurel in People
v. Vera requiring that it must be based on substantial distinctions which make real differences it must be
germane to the purposes of the law it must not be limited to existing conditions only, and must apply
equally to each member of the class.
To repeat, the Constitution specifically makes mention of the creation of a special court, the
Sandiganbayan, precisely in response to a problem, the urgency of which cannot be denied, namely,
dishonesty in the public service. It follows that those who may thereafter be tried by such court ought to
have been aware as far back as January 17, 1973, when the present Constitution came into force, that a
different procedure for the accused therein, whether a private citizen as petitioner is or a public official, is
not necessarily offensive to the equal protection clause of the Constitution. Petitioner, moreover, cannot be
unaware of the ruling of this Court in Co Chiong v. Cuaderno, a 1949 decision, that the general guarantees
of the Bill of Rights, included among which are the due process of law and equal protection clauses must
give way to [a] specific provision, in that decision, one reserving to Filipino citizens of the operation of
public services or utilities. The scope of such a principle is not to be constricted. It is certainly broad
enough to cover the instant situation.
Philippine Judges Association vs. Prado
227 SCRA 703 (1993)
Facts:
The Philippine Judges Association are members of the lower courts who feel that their official
functions as judges will be prejudiced by the measures of Section 35 of R.A. No. 7354 as implemented by
the Philippine Postal Corporation through its Circular No. 9228. These measures withdraw the franking
privilege from the Supreme Court, the Court of Appeals, the Regional Trial Courts, the Metropolitan Trial
Courts, the Municipal Trial Courts, and the Land Registration Commission and its Registers of Deeds,
along with certain other government offices. It is alleged that R.A. No. 7354 is discriminatory because
while withdrawing the franking privilege from the Judiciary, it retains the same for the President of the
Philippines, the Vice President of the Philippines, Senators and Members of the House of Representatives,
the Commission on Elections, former Presidents of the Philippines; the National Census and Statistics
Office, and the general public in the filing of complaints against public offices and officers.
Issue: Whether or not Sec. 35 of RA 7354 is discriminatory and encroaches on the independence of the
judiciary.
Ruling:
Yes. Sec. 35 of RA 7354 is discriminatory and encroaches on the independence of the Judiciary.
The equal protection of the laws is embraced in the concept of due process, as every unfair discrimination
offends the requirements of justice and fair play. It has nonetheless been embodied in a separate clause in
Article III, Sec. 1, of the Constitution to provide for a more specific guaranty against any form of undue
favoritism or hostility from the government. Arbitrariness in general may be challenged on the basis of the
due process clause. But if the particular act assailed partakes of an unwarranted partiality or prejudice, the
sharper weapon to cut it down is the equal protection clause.
According to a long line of decisions, equal protection simply requires that all persons or things
similarly situated should be treated alike, both as to rights conferred and responsibilities imposed. Similar
subjects, in other words, should not be treated differently, so as to give undue favor to some and unjustly
discriminate against others. The equal protection clause does not require the universal application of the
laws on all persons or things without distinction. This might in fact sometimes result in unequal protection,
as where, for example, a law prohibiting mature books to all persons, regardless of age, would benefit the
morals of the youth but violate the liberty of adults. What the clause requires is equality among equals as
determined according to a valid classification. By classification is meant the grouping of persons or things
similar to each other in certain particulars and different from all others in these same particulars.
In lumping the Judiciary with the other offices from which the franking privilege has been
withdrawn, Section 35 has placed the courts of justice in a category to which it does not belong. If it
recognizes the need of the President of the Philippines and the members of Congress for the franking
privilege, there is no reason why it should not recognize a similar and in fact greater need on the part of the
Judiciary for such privilege. While we may appreciate the withdrawal of the franking privilege from the
Armed Forces of the Philippines Ladies Steering Committee, we fail to understand why the Supreme Court
should be similarly treated as that Committee. And while we may concede the need of the National Census
and Statistics Office for the franking privilege, we are intrigued that a similar if not greater need is not
recognized in the courts of justice.
We are unable to agree with the respondents that Section 35 of R.A. No. 7354 represents a valid
exercise of discretion by the Legislature under the police power. On the contrary, we find its repealing
clause to be a discriminatory provision that denies the Judiciary the equal protection of the laws guaranteed
for all persons or things similarly situated. The distinction made by the law is superficial. It is not based on
substantial distinctions that make real differences between the Judiciary and the grantees of the franking
privilege.

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