G.R. No. 1127 : April 28, 1903
THE UNITED STATES, complainant-appellee, vs. BIAN JENG, defendant-appellant.

FACTS:
Bian Jeng was convicted of cocheco in the Municipal Court for the north of Manila. He appealed to the Court of First Instance, where he was again convicted. He then appealed to the Supreme Court. The Government moved to dismiss the appeal, arguing that no appeal lies from a judgment of the Court of First Instance of Manila rendered on appeal from a municipal court, except in cases involving the validity or constitutionality of a statute. The Government contended that the present case did not fall under that exception, as the appeal merely questioned the sufficiency of the evidence to prove the offense, not the constitutionality or validity of the statute under which Bian Jeng was convicted.

ISSUE:
Whether an appeal to the Supreme Court is permissible from a judgment of the Court of First Instance of Manila rendered on appeal from a municipal court in a criminal case that does not involve the validity or constitutionality of a statute.

RULING:
No. The Supreme Court dismissed the appeal. It held that, under the applicable laws, no appeal lies to the Supreme Court from a judgment of the Court of First Instance rendered on appeal from a municipal court (which replaced the former justice of the peace courts in Manila) in a criminal case, unless the case involves the validity or constitutionality of a statute. The Court reasoned that although the municipal courts were created by a subsequent law ( Act No. 183 ), they exercised the same criminal jurisdiction as the former justice of the peace courts. The legislative intent was to maintain the same limitation on appeals from these inferior tribunals, ensuring uniformity throughout the archipelago. Since Bian Jeng’s appeal raised no constitutional or statutory validity issue, but only the sufficiency of the evidence, the Supreme Court lacked appellate jurisdiction. The appeal was dismissed, with costs against the appellant.