GR 26199; (March, 1970) (Digest)
G.R. No. L-26199, L-26200, L-26201, L-26202, L-26203, L-26204, L-26205, L-26206 March 30, 1970.
Case Parties: THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. RUFINO VILLANUEVA, defendant-appellee; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. BALTAZAR BURLATAN, defendant-appellee; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. APOLONIO CARPILA, defendant-appellee; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. SALVADOR LABIAGA, ET AL., defendants-appellees; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. RECOMENDADO ONTOLAN, ET AL., defendants-appellees; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. GENOVEVA BURLAT DE BALIAO, defendant-appellee; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. PEDRO GUMISAD, ET AL., defendants-appellees; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. JACINTO LOMOLJO, defendant-appellee.
FACTS
The Court of First Instance (CFI) of Misamis Occidental issued separate orders in 1963 and 1964 “delegating” or assigning eight criminal cases to the Municipal Court of Oroquieta (the provincial capital) for trial and judgment due to the many pending cases in the CFI. Five of these cases were on appeal to the CFI from judgments of conviction rendered by several other municipal courts. The other three were original cases filed directly with the CFI. Upon objection by the accused’s counsel questioning the municipal court’s jurisdiction, it returned the cases to the CFI. The CFI, in a consolidated order dated September 11, 1965, sent all eight cases back to the Municipal Court of Oroquieta for “trial and final disposition.” Thereafter, the municipal court issued an order dismissing the cases “for lack of jurisdiction.” The Provincial Fiscal’s motion for reconsideration was denied. After procedural disputes regarding the proper mode of appeal and a mandamus case, the records were elevated to the Supreme Court.
ISSUE
Whether the Municipal Court of Oroquieta had jurisdiction to try and decide the eight criminal cases assigned to it by the Court of First Instance of Misamis Occidental.
RULING
The Municipal Court of Oroquieta had no jurisdiction. The Supreme Court held that the order of assignment issued by the CFI was void and ineffective. At the time of the assignments, the applicable law was Republic Act No. 3828 , which amended Section 87 of the Judiciary Act. As amended, the jurisdiction of justices of the peace in provincial capitals (and municipal judges) to try cases concurrently with the CFI was limited to offenses “committed within their respective jurisdictions,” meaning within their territorial limits. The offenses charged in the eight cases were committed in other municipalities, not within Oroquieta’s jurisdiction. Furthermore, with respect to the five cases that were on appeal to the CFI, the municipal court could not possibly exercise appellate jurisdiction, whether by delegation or concurrently. The order of dismissal issued by the municipal court was likewise without legal effect. The status of the cases was as if they had never been assigned or dismissed and had remained pending in the CFI. The Supreme Court ordered the records remanded to the Court of First Instance of Misamis Occidental for further proceedings.