RUFINO V.

NUÑEZ
vs.
SANDIGANBAYAN and PEOPLE OF THE PHILIPPINES
G.R. Nos. L-50581-50617 January 30, 1982

NATURE OF ACTION:

Petition for Certiorari and Prohibition on the validity of the creation of the Sandiganbayan through
Presidential Decree 1486, as amended as it is violative of due process, equal protection and ex post facto
law.

MATERIAL FACTS:

Petitioner, Rufino Nunez was accused before the Sandiganbayan of estafa through falsification of public and
commercial documents committed in connivance with his other co-accused who are all public officials, in
several cases. Petitioner assailed that PD 1486 is violative of the due process, equal protection, and ex post
facto clauses of the Constitution. He claims that the Sandiganbayan proceedings violates the right to equal
protection, because appeal as a matter of right,was reduced into a mere matter of discretion and appeal
likewise was limited only to questions of law, excluding a review of the facts and evidence; and there is only
one chance to appeal conviction, by certiorari to the SC, instead of the traditional two chances; while all
other estafa indictees are entitled to appeal as a matter of right covering both law and facts and to two
appellate courts, first to the CA and thereafter to the SC. The contention that the challenged Presidential
Decree is contrary to the ex post facto provision of the Constitution is similarly premised on the allegation
that "petitioner's right of appeal is being diluted or eroded efficacy wise.
ISSUES:

Whether or not the creation of the Sandiganbayan is a violation of the Equal Protection clause in the
Constitution

RULING:
This Court holds that petitioner has been unable to make a case calling for a declaration of
unconstitutionality of Presidential Decree No. 1486 as amended by Presidential Decree No. 1606. The
decision does not go as far as passing on any question not affecting the right of petitioner to a trial with all
the safeguards of the Constitution. WHEREFORE, the petition is dismissed. No costs.

RATIO DECIDENDI:

Presidential Degree 1486 paved way to the creation of a special court which shall take jurisdiction
of cases involving public officials charged with graft and corruption. The creation of such court as provided
in the 1973 Constitution is a response to the urgency of rampant dishonesty in public service. The court
ruled that such special court requiring a different and specific procedure for the accused is not necessary
violative of equal protection for as long as it complies with the requisites set forth by the constitution on
Equal Protection. The following are the requisites for valid classification under the Equal Protection clause:
“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.”. It is for this reason that the court dismissed the petition.