GR 43154; (November, 1935) (Digest)
G.R. No. 43154 ; November 7, 1935
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellant, vs. CO HIOK (alias FELIX BENITEZ), defendant-appellee.
FACTS
The defendant was charged in the justice of the peace court of Pagsanjan, Laguna, with “less serious physical injuries through reckless imprudence,” the complaint alleging the injuries would take 25 days to heal. After trial, the justice of the peace court found the injuries actually took 41 days to heal but still convicted the defendant of the less serious charge and imposed a penalty within its jurisdiction. The defendant appealed to the Court of First Instance (CFI) of Laguna. The provincial fiscal then filed a new information in the CFI, charging the defendant with serious physical injuries through reckless imprudence based on the 41-day healing period. The defendant moved to dismiss, arguing both courts lacked jurisdiction. The CFI granted the motion, dismissing the case without prejudice.
ISSUE
Did the Court of First Instance of Laguna err in dismissing the case for lack of jurisdiction on appeal from the justice of the peace court?
RULING
Yes. The Supreme Court reversed the CFI’s order. The jurisdiction of a court in criminal cases is determined by the allegations in the complaint, not by the evidence presented or the findings at trial. Therefore, the justice of the peace court had original jurisdiction based on the allegations in its complaint. On appeal, the CFI acquires jurisdiction based on the original complaint filed in the justice of the peace court; a new information is unnecessary and, in this case, was improper as it changed the nature of the crime charged. The CFI erred in considering the new information and in holding it lacked jurisdiction. It should have tried the case on appeal based on the original complaint. The case was remanded to the CFI to try and decide it under its appellate jurisdiction.
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