GR L 2922 3; (June, 1950) (Digest)
G.R. No. L-2922 and L-2923; June 23, 1950
PEOPLE OF THE PHILIPPINES vs. EMILIANO PEÑAS, Y FERRER and PEOPLE OF THE PHILIPPINES vs. LAUREANO REY Y ROCHA
FACTS
The accused were charged with qualified theft of property not exceeding P200 in value in the Court of First Instance (CFI) of Rizal, Quezon City Branch. The penalty for the crime is prision correccional in its full extent (6 months and 1 day to 6 years). The trial judge, Ceferino de los Santos, dismissed the informations in both cases for alleged lack of jurisdiction, prompting the fiscal to appeal.
ISSUE
Whether the original jurisdiction conferred on justices of the peace and judges of municipal courts by Section 87(c) of Republic Act No. 296 (The Judiciary Act of 1948) over certain criminal cases, including theft where the amount involved does not exceed P200, is exclusive or concurrent with the Court of First Instance.
RULING
The Supreme Court reversed the orders of dismissal. The jurisdiction granted to justices of the peace and municipal judges under Section 87(c) of the Judiciary Act is concurrent with the Courts of First Instance. The Court, citing its recent decision in People vs. Francisco Palmon, held that Section 44(f) of the same Act expressly confers original jurisdiction on CFIs over all criminal cases where the penalty is imprisonment for more than six months. To construe Section 87(c) as granting exclusive jurisdiction to inferior courts would nullify Section 44(f). The statute must be interpreted to harmonize all its provisions. The cases were remanded to the court of origin for further proceedings.
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