GR 159098; (October, 2006) (Digest)
G.R. No. 159098 ; October 27, 2006
SPS. HENRY and ROSARIO UY, petitioners, vs. HON. JUDGE ARSENIO P. ADRIANO, in his capacity as Pairing Judge of RTC, Br. 64, Tarlac City, CITY PROSECUTOR ALIPIO C. YUMUL and PIÑAKAMASARAP CORP., respondents.
FACTS
Petitioners Henry and Rosario Uy were charged with unfair competition under Article 189 of the Revised Penal Code before the Municipal Trial Court (MTC) of Tarlac City. The Information alleged they manufactured and sold soy sauce using the registered trademark “Marca Piña” of private respondent Piñakamasarap Corporation. After arraignment and plea of not guilty, the MTC proceeded with trial. During the pendency, Supreme Court Administrative Order No. 104-96 was issued, conferring exclusive original jurisdiction over such intellectual property violations to the Regional Trial Courts (RTC). Despite this, the MTC continued the proceedings for several years, allowing the prosecution to present witnesses and eventually rest its case. Petitioners, through new counsel, then filed a motion for leave to file a demurrer to evidence.
ISSUE
Whether the MTC lost jurisdiction over the case upon the issuance of A.O. No. 104-96, rendering all subsequent proceedings null and void.
RULING
Yes. The Supreme Court ruled that jurisdiction is conferred by law. A.O. No. 104-96 explicitly withdrew the jurisdiction of Metropolitan Trial Courts and Municipal Trial Courts in Cities over violations of Articles 188 and 189 of the Revised Penal Code and vested exclusive jurisdiction in the Regional Trial Courts. This administrative order took effect upon its issuance. Consequently, the MTC was divested of authority to further act on the case, except to dismiss it. All proceedings conducted by the MTC after the effectivity of the order, including the reception of prosecution evidence and the resolution of the demurrer, were null and void for lack of jurisdiction. The Court emphasized that jurisdiction over the subject matter cannot be waived or conferred by the acquiescence of the parties. The petition was granted, and the criminal case was ordered dismissed without prejudice to its refiling in the proper court.