G.R. No. L-40902 February 18, 1976
THE PEOPLE OF THE PHILIPPINES, petitioner, vs. HONORABLE JUDGE AMANTE P. PURISIMA, COURT OF FIRST INSTANCE OF MANILA, BRANCH VII, and JOSEFA PESIMO, respondents.

FACTS

The City Fiscal of Manila filed an information against private respondent Josefa Pesimo before the Court of First Instance (CFI) of Manila for violating the Civil Register Law. The charge alleged that Pesimo knowingly made false statements in her son’s Certificate of Live Birth by falsely representing him as legitimate and herself as married. The prescribed penalty for the offense is imprisonment of one month to six months, or a fine of P200 to P500, or both, at the court’s discretion.
Respondent Judge Purisima dismissed the case ex mere motu, holding that the CFI lacked jurisdiction. The court reasoned that since the maximum imprisonment prescribed is only six months, the penalty fell below the floor of its original criminal jurisdiction, which it believed began only for offenses punishable by imprisonment exceeding six months. The court concluded that exclusive jurisdiction belonged to the City Court of Manila. The prosecution’s motion for reconsideration was denied, prompting the People to elevate the case via certiorari.

ISSUE

Whether the Court of First Instance correctly dismissed the criminal case for lack of jurisdiction, given that the prescribed penalty is imprisonment of one to six months or a fine of P200 to P500.

RULING

The Supreme Court reversed the respondent court’s orders and held that it had jurisdiction. The ruling is anchored on the statutory framework of concurrent jurisdiction between CFIs and inferior courts. Under Section 44(f) of the Judiciary Act, CFIs have original jurisdiction in criminal cases where the penalty provided is imprisonment for more than six months or a fine of more than P200. Conversely, Section 87(c) grants municipal and city courts jurisdiction over offenses with penalties up to certain thresholds.
The Court clarified that the exclusive original jurisdiction of municipal and city courts is confined to offenses where the penalty is imprisonment for six months or less or a fine of P200 or less. Once the penalty exceeds these minima—such as a fine exceeding P200, as in this case where the fine can go up to P500—jurisdiction becomes concurrent with the CFI. The offense charged prescribes a fine of “not less than P200 nor more than P500.” Since the fine can be more than P200, the condition in Section 44(f) for CFI jurisdiction (“a fine of more than two hundred pesos”) is satisfied, thereby conferring concurrent jurisdiction.
The Court further explained that the 1963 amendments expanding inferior court jurisdiction did not divest CFIs of their concurrent jurisdiction under Section 44(f). There is no constitutional bar to concurrent jurisdiction over the same offense. Finally, applying the axiom that where courts have concurrent jurisdiction, the court which first acquires it retains exclusive jurisdiction, the filing of the information with the CFI vested it with authority to try the case. The case was remanded for trial on the merits.