G.R. No. 2815
THE UNITED STATES, Plaintiff-Appellee, vs. BRIGIDO SALVADOR AND ALFONSO CAGUINGUING, Defendants-Appellants.
September 11, 1906 | Carson, J.

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FACTS:
1. Prosecution & Trial:
– Brigido Salvador and Alfonso Caguinguing were charged with asesinato (murder) in the Court of First Instance of Manila.
– The case against Salvador was dismissed due to insufficient evidence, resulting in his acquittal.
– Caguinguing was convicted and sentenced to death.

2. Jurisdictional Issue:
– The crime allegedly occurred in San Francisco del Monte, an area within the five-mile police jurisdiction zone around Manila under Act No. 183 of the Philippine Commission.
– The Supreme Court had previously ruled (e.g., United States v. Jenkins) that Act No. 183 did not extend the judicial jurisdiction of Manila courts to crimes committed in this zone.

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ISSUE:
Whether the Court of First Instance of Manila had jurisdiction over the crime of asesinato committed outside Manila but within its five-mile police jurisdiction zone under Act No. 183.

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RULING:
1. Lack of Jurisdiction:
– The Supreme Court reversed Caguinguing’s conviction, holding that the trial court lacked jurisdiction over the offense.
– Act No. 183 granted Manila police powers over the zone but did not confer judicial jurisdiction to try crimes committed there.

2. Disposition:
– The judgment and death sentence were declared void.
– However, since there was evidence of Caguinguing’s guilt, he was remanded to a court of competent jurisdiction for retrial under Section 23 of General Orders No. 58.

3. Concurrence:
– The decision was unanimous, with Justices Arellano, Torres, Mapa, Willard, and Tracey concurring.

Key Precedent Cited: United States v. Jenkins (5 Phil. Rep., 278).

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Final Note: The case underscores the distinction between police jurisdiction and judicial jurisdiction, emphasizing that statutory grants of authority must be explicit to extend court jurisdiction beyond territorial limits.