G.R. No. L-35825 February 20, 1989
CORA LEGADOS, represented by ROSA LEGADOS, and HON. JESUS ANGELES, petitioners, vs. HON. DOROTEO DE GUZMAN, Judge, CFI, Br. II, Zamboanga, VILMOR ICAO, represented by his mother, SOFIA L. ICAO, respondents.

FACTS

On March 6, 1972, a complaint for simple seduction was filed with the City Court of Dipolog against respondent Vilmor Icao. An information was subsequently filed by the First Assistant City Fiscal. After pleading not guilty, Icao moved to quash the information, arguing that the City Court lacked jurisdiction over the offense of simple seduction. The City Court, presided by petitioner Judge Jesus Angeles, denied the motion.
Icao then filed a petition for prohibition with the Court of First Instance of Zamboanga, presided by respondent Judge Doroteo de Guzman. The CFI granted the petition and permanently enjoined the City Court from proceeding with the criminal case. This Order, dated October 9, 1972, is now assailed by petitioners as having been rendered with grave abuse of discretion.

ISSUE

Whether the City Court (now Municipal Trial Court) had jurisdiction to try the crime of simple seduction at the time it denied the motion to quash and was subsequently enjoined by the CFI.

RULING

The Supreme Court ruled that the CFI’s Order issuing the writ of prohibition was correct based on the prevailing jurisprudence at the time it was rendered. The long-standing doctrine, established in U.S. v. Bernardo (1911), held that inferior courts had no jurisdiction over simple seduction. This was because conviction for this crime carried with it, under Article 345 of the Revised Penal Code, the civil liability to acknowledge and support the offspring. This potential civil liability, irrespective of its actual occurrence or the amount involved, was deemed to place the case beyond the jurisdiction of inferior courts.
However, the Court emphasized that this doctrine was subsequently altered by legislation. Batas Pambansa Blg. 129, which took effect on August 14, 1981, explicitly granted Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts exclusive original jurisdiction over all offenses punishable with imprisonment not exceeding four years and two months, including the civil liability arising from such offenses, “irrespective of kind, nature, value, or amount thereof.” This statutory provision superseded the old Bernardo doctrine. Consequently, simple seduction now clearly falls within the jurisdiction of first-level courts.
Therefore, while the CFI’s 1972 Order was legally sound under the old rule, the legal landscape has changed. The Supreme Court set aside the assailed Order and remanded the case to the Municipal Trial Court of Dipolog City (the successor of the City Court) for further proceedings, in accordance with the new jurisdiction established by B.P. Blg. 129. The decision was declared immediately executory.