G.R. No. L-20347; October 31, 1964
Ildefonso Brecinio, petitioner-appellant, vs. Nicolas Papica, Justice of the Peace, Pili, Camarines Sur, et al., respondents-appellees.

FACTS

Petitioner Ildefonso Brecinio was charged with qualified theft of a carabao valued at P150.00 before the Justice of the Peace Court of Pili, Camarines Sur. Brecinio moved to dismiss the case, asserting that the justice of the peace court lacked jurisdiction. He argued that since the penalty for qualified theft of large cattle is prision mayor in its medium degree to reclusion temporal in its minimum degree—a penalty exceeding six months—exclusive jurisdiction vested in the Court of First Instance.
The Justice of the Peace, respondent Judge Nicolas Papica, denied the motion, ruling that his court had original jurisdiction concurrent with the Court of First Instance. Brecinio elevated the matter via certiorari to the Court of First Instance of Camarines Sur. That court dismissed his petition, upholding the concurrent jurisdiction of the justice of the peace court and noting that since the latter court first took cognizance of the case, it properly retained authority to try and decide it. Brecinio appealed directly to the Supreme Court.

ISSUE

Whether a justice of the peace court has jurisdiction to try a case for qualified theft of large cattle where the value of the property does not exceed P200.00.

RULING

Yes, the justice of the peace court has concurrent original jurisdiction with the Court of First Instance. The Supreme Court affirmed the lower court’s dismissal, holding the appeal to be without merit and merely dilatory.
The legal logic is anchored on the Judiciary Act of 1948, as amended. Section 87(b)(3) of the Act grants justice of the peace courts jurisdiction over “[l]arceny, embezzlement and estafa where the amount of money or property stolen, embezzled or otherwise involved does not exceed the sum or value of two hundred pesos.” The Court has consistently ruled, beginning with cases like People v. Palmon (1950), that for offenses enumerated in this section, jurisdiction is concurrent with the Court of First Instance when the prescribed penalty exceeds six months imprisonment or a P200.00 fine. Qualified theft, as a form of larceny, falls under this provision when the value involved is P200.00 or less, irrespective of the prescribed penalty for the qualified form.
The Court rejected the appellant’s reliance on an obiter dictum from a Court of Appeals decision (People v. Bacolongan), which suggested jurisdiction depended solely on the penalty. The Supreme Court clarified that in case of conflict, its own settled doctrine prevails. The jurisdictional test under the Judiciary Act for the listed crimes is the value of the property, not the abstract penalty for the offense. Since the stolen carabao was valued at P150.00 (below the P200.00 threshold), the justice of the peace court properly exercised its concurrent jurisdiction. The Court found no reason to depart from its established jurisprudence.