COMELEC vs. NOYNAY ( 292 SCRA 254 ) Election Offense, B.

Jurisdiction Over Election OffensesFacts: In an Order issued on 25 August 1997, respondent Judge Tomas B. Noynay,as presiding judge of Branch 23, motu proprio ordered the records of the cases to bewithdrawn and directed the Comelec Law Department to file the cases with theappropriate Municipal Trial Court on the ground that pursuant to Section 32 of B.P.Blg. 129 as amended by R.A. no. 7691, the Regional Trial Court has no jurisdictionover the cases since the maximum imposable penalty in each of the cases does notexceed six years of imprisonment.I s s u e : W h e t h e r o r n o t R . A . N o . 7 6 9 1 h a s d i v e s t e d R e g i o n a l T r i a l C o u r t s o r jurisdiction over election offenses, which are punishable with imprisonment of notexceeding six years.Held: By virtue of the exception provided for in opening sentence of section 32 of B.P. Blg. 129, the exclusive original jurisdiction of Metropolitan Trial Courts, MunicipalTrial Courts and Municipal Circuit Courts does not cover those criminal cases whichby specific provisions of law fall within the exclusive original jurisdiction of RegionalTrial Courts and of the Sandiganbayan, regardless of the penalty prescribed therefor.Pursuant to Section 268 of the Omnibus Election Code, election offenses also fallwithin the exception provided for in the opening sentence of Section 32 of BatasP a m b a n s a 1 2 9 . Republic Act 7691 can by no means be considered as a special law on jurisdiction it is merely an amendatory law intended to amend specific sections of the JudiciaryReorganization Act of 1980 and it does not have the effect of repealing laws vestingupon the Regional trial Courts or the Sandiganbayan exclusive original jurisdiction toheart and decide the cases therein specified.Congress may thus provide by law that a certain class of cases should be exclusivelyheard and determined by one court. Such law would be a special law and must beconstrued as an exception to the general law on jurisdiction of courts. However, Congress never intended that R. A. no. 7691 should repeal such special provisions isindubitably evident from the fact that it did not touch at all the opening sentence of Section 32 of B.P. Blg. 129 providing for the exception.