G.R. No. 177960 January 29, 2009
JEFFREY RESO DAYAP, Petitioner, vs. PRETZY-LOU SENDIONG, GENESA SENDIONG, ELVIE SY and DEXIE DURAN, Respondents.

FACTS

An Information was filed charging petitioner Jeffrey Reso Dayap with Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries, and Damage to Property. The Information alleged that on December 28, 2004, in Sibulan, Negros Oriental, petitioner drove a cargo truck in a reckless manner, hitting a Colt Galant, causing the death of Lou Gene R. Sendiong, less serious physical injuries to Dexie Duran and Elvie Sy, and damage to the Colt Galant. Petitioner pleaded not guilty before the Municipal Trial Court (MTC). Respondents filed a motion to amend the Information to add an allegation of abandonment, but the Provincial Prosecutor withdrew this motion. After the prosecution rested, petitioner filed a Demurrer to Evidence. The MTC granted the demurrer and acquitted petitioner, finding that the prosecution failed to prove the allegations: the accused was not identified as the driver; the death, injuries, and property damage were not established with evidence like a death certificate, medical certificates, or proof of damage. The MTC also noted evidence suggested the Colt Galant swerved into the truck’s lane. Respondents filed a petition for certiorari with the Regional Trial Court (RTC). The RTC affirmed the acquittal but remanded the case to the MTC for further proceedings on the civil aspect, as the acquittal did not declare the facts for civil liability did not exist. Respondents then filed a petition for review with the Court of Appeals. The Court of Appeals ruled that, with no proof of the total value of the property damaged and with a claim for civil damages of ₱1,500,000.00, the case fell under RTC jurisdiction, not MTC jurisdiction, and remanded the case to the RTC for proper disposition. Petitioner moved for reconsideration, which was denied.

ISSUE

Whether the Court of Appeals erred in ruling that the RTC, not the MTC, had jurisdiction over the criminal case for Reckless Imprudence resulting in Homicide, Less Serious Physical Injuries, and Damage to Property.

RULING

The Supreme Court ruled that the Court of Appeals erred. Jurisdiction over the offense is determined by the allegations in the Information. The Information alleged damage to property through reckless imprudence, which, under the law at the time of filing (BP 129), fell within the exclusive original jurisdiction of the MTC if the imposable fine did not exceed ₱20,000.00 (increased by RA 7691). Since the Information did not specify the amount of damage, it was presumed to be within the MTC’s jurisdiction. The claim for civil damages in a separate civil action does not affect the criminal court’s jurisdiction. The MTC properly acquired jurisdiction. The Supreme Court reversed the Court of Appeals Decision and Resolution and reinstated and affirmed the RTC Order which had affirmed the MTC’s acquittal of petitioner.