G.R. No. L-26457 March 25, 1970
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. CESAR TAYAO, ET AL., defendants-appellees.

FACTS

The accused, Cesar Tayao, Pablo Piadoso, Alberto Valencia, and Gerardo Daquez, were charged with the crime of grave coercion in an information filed on January 13, 1966, with the Court of First Instance of Nueva Ecija. The accused filed a motion to quash the information on August 25, 1966, contending that the original and exclusive jurisdiction to try the offense was vested in the municipal court of San Jose, Nueva Ecija, where the crime was allegedly committed. The lower court sustained the motion to quash in its order of August 4, 1966, agreeing that the matter was within the original jurisdiction of the municipal court, and dismissed the case. The provincial fiscal appealed directly to the Supreme Court, the question being one of law.

ISSUE

Whether the Court of First Instance of Nueva Ecija has jurisdiction over the offense of grave coercion, or if exclusive jurisdiction is vested in the municipal court.

RULING

The Supreme Court ruled that the Court of First Instance has jurisdiction. The offense of grave coercion, punishable with arresto mayor (imprisonment from one month and one day to six months) and a fine not exceeding P500.00, falls within the area of concurrent jurisdiction of municipal or city courts and courts of first instance. This doctrine was established in Esperat v. Avila and reiterated in People v. Dalton. Consequently, the lower court erred in dismissing the case based on a mistaken assumption of lack of jurisdiction. The order of dismissal dated August 4, 1966, was set aside, and the case was remanded to the lower court for further proceedings.