G.R. No. L-2700; January 13, 1950
People of the Philippines vs. Manuel Blanco, Judge of the Court of First Instance of Iloilo

FACTS

The City Fiscal of Iloilo filed an information in the municipal court against Claudio Galicto and Roberto Sevilla for the crime of theft of two trousers valued at P28, with an allegation that they were habitual delinquents due to three previous convictions. Galicto pleaded guilty. The municipal judge, believing he lacked jurisdiction, forwarded the case to the Court of First Instance (CFI). The fiscal moved for the case’s return to the municipal court, arguing it had jurisdiction. The CFI, presided by respondent Judge Manuel Blanco, denied the motion.

ISSUE

Whether the municipal court of Iloilo or the Court of First Instance has jurisdiction over a theft case where the value of the stolen property is within the municipal court’s jurisdictional limit (P28), but where the accused is charged as a habitual delinquent, potentially increasing the penalty.

RULING

The municipal court of Iloilo has jurisdiction. The jurisdiction of the municipal court of Iloilo over theft cases is determined by the value of the property stolen (not exceeding P200), not by the penalty that may be imposed. Habitual delinquency is not a crime itself but merely a factor in determining the total penalty under Article 62 of the Revised Penal Code. Since the municipal court first acquired jurisdiction, it retains it to the exclusion of others. The respondent judge is prohibited from taking cognizance of the case, which must be returned to the municipal court for further proceedings.

AI Generated by Armztrong.