G.R. No. L-44113 March 31, 1977
PEOPLE OF THE PHILIPPINES, petitioner, vs. HON. JUDGE MERICIA B. PALMA and ROMULO INTIA Y MORADA, respondents.

FACTS

Respondent Romulo Intia y Morada, aged 17, was charged with vagrancy before the City Court of Naga, presided over by respondent Judge Mericia B. Palma. The City Fiscal filed the information on February 10, 1976. In an Order dated March 6, 1976, respondent judge dismissed the case, ruling that her court lacked jurisdiction. She held that Presidential Decree No. 603, the Child and Youth Welfare Code, which defines a youthful offender as one over nine but under twenty-one years of age, had by implication transferred jurisdiction over such accused persons from the regular courts to the Juvenile and Domestic Relations Court (JDRC) for Camarines Sur. The prosecution, sharing the view of the presiding judge of the JDRC, maintained that jurisdiction remained with the regular courts, prompting this petition.

ISSUE

Whether the issuance of P.D. No. 603 transferred jurisdiction over criminal cases where the accused is sixteen years old but under twenty-one from the regular courts to the Juvenile and Domestic Relations Court.

RULING

The Supreme Court ruled in the negative, setting aside the dismissal orders and reinstating the case in the City Court. The legal logic is anchored on statutory construction and the nature of jurisdictional grants. Republic Act No. 6591, which created the JDRC for Camarines Sur, expressly and specifically limited its criminal jurisdiction to cases “wherein the accused is under sixteen years of age at the time of the filing of the case.” This is a special law conferring limited jurisdiction on a special court. P.D. No. 603, a general law on child and youth welfare, while defining “youthful offender” more broadly, did not contain any express provision repealing or amending the jurisdictional grant in R.A. 6591.
A general law cannot repeal a special law by mere implication; the repeal must be express and specific. The enlargement of a court’s special and limited jurisdiction must positively appear in clear terms. The mere definition in P.D. 603 did not operate to withdraw jurisdiction from the regular courts. This interpretation is bolstered by P.D. No. 798, issued later, which in its provisions on confinement applications distinguished between filing with the Court of First Instance (for general cases) and the JDRC specifically for youths “under 16 years of age.” The policy of rehabilitating youthful offenders under 21 is served by applying the substantive guidelines of P.D. 603 regardless of whether the trial court is the JDRC (for those under 16) or the regular court (for those 16 to under 21), a classification deemed not unreasonable. Jurisdiction is conferred by law, and absent an express statutory transfer, the City Court retained its jurisdiction.