Defining Manager Expands Sandiganbayan Jurisdiction Over Graft Cases Involving Government Owned Corporations

The Court also rejected the Sandiganbayan's application of the doctrine of noscitur a sociis, which suggests that the meaning of a word may be determined by the company it keeps. The Sandiganbayan argued that because "manager" appeared alongside "presidents, directors or trustees," the term should be limited to officers with overall control of the corporation. The Supreme Court disagreed, noting that directors and trustees do not exercise overall supervision and control—they merely lay down policies when acting collectively as a board. Since managers have different responsibilities from directors and trustees, they belong to a distinct class of corporate officers.

The Court also addressed Bello's argument that his rank as Police Superintendent in the Philippine National Police should exclude him from the Sandiganbayan's jurisdiction. The Court clarified that what matters is that the offense was committed in relation to his office as manager of the Legal Department of AFP-RSBS, not his police rank.

Practical takeaways

• The term "manager" under Section 4(a)(1)(g) of R.A. 8249 includes heads of departments or divisions within a GOCC, not just those with overall corporate control.
• The Sandiganbayan's jurisdiction over graft cases involving GOCCs extends to department-level officers who commit offenses in relation to their office.
• The doctrine of noscitur a sociis does not automatically limit the meaning of "manager" to top-level executives when the context and purpose of the law suggest otherwise.
• An accused's rank in another government agency does not remove the case from the Sandiganbayan's jurisdiction if the offense was committed in relation to a covered position in a GOCC.
• GOCCs created by special law to perform public functions fall within the Sandiganbayan's jurisdiction regardless of their corporate structure.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.