GR 154557; (February, 2008) (Digest)
G.R. No. 154557 ; February 13, 2008
PEOPLE OF THE PHILIPPINES, petitioner, vs. The HONORABLE COURT OF APPEALS, 12th DIVISION, RICO LIPAO, and RICKSON LIPAO, respondents.
FACTS
On February 24, 1992, private respondents Rico and Rickson Lipao were charged before the Regional Trial Court (RTC) of Surigao City with violation of Section 68 of Presidential Decree No. 705 (The Forestry Code), as amended, for possessing forest products without legal documents. The offense was punishable under Articles 309 and 310 of the Revised Penal Code. The RTC proceeded with the trial and, on July 25, 1994, rendered a judgment convicting the accused. During the pendency of the case, Republic Act No. 7691 took effect on April 15, 1994, expanding the jurisdiction of first-level courts (MTCs, MeTCs, MCTCs) to include offenses punishable by imprisonment not exceeding six years.
On appeal, the Court of Appeals (CA) did not rule on the merits. Instead, in its June 13, 2002 Decision, it set aside the RTC judgment and dismissed the criminal case. The CA held that the RTC lost jurisdiction over the case upon the effectivity of R.A. No. 7691 . It reasoned that since the penalty for the offense, as applied to the value of the forest products (P3,100.00), fell within the new jurisdictional threshold for first-level courts, the RTC no longer had authority to decide the case.
ISSUE
Whether or not the Court of Appeals erred in dismissing the criminal case on the ground that the RTC lost jurisdiction due to the passage of R.A. No. 7691 , which took effect before the RTC rendered its judgment.
RULING
Yes, the Court of Appeals erred. The Supreme Court reversed the CA decision and reinstated the RTC’s judgment of conviction. The core legal principle is that jurisdiction, once acquired by a court over a case, continues until its final termination and is not affected by subsequent legislation altering jurisdictional boundaries, unless the statute expressly provides for retroactive application.
R.A. No. 7691 contains no provision stating that it applies to pending cases. Jurisdiction is determined by the law in force at the time of the commencement of the action. The RTC validly acquired jurisdiction over Criminal Case No. 551 when the Information was filed in 1992, at which time the offense, based on the alleged value and the prescribed penalty, fell within its original jurisdiction. The subsequent expansion of first-level court jurisdiction did not divest the RTC of its already vested authority to hear, try, and decide the case to its conclusion. The CA’s dismissal was a patent nullity for depriving the State of its right to prosecute and for disregarding the doctrine of continuity of jurisdiction. The case was remanded to the CA to resolve the appeal on its merits.