GR 45815; (May, 1990) (Digest)
G.R. No. 45815, May 18, 1990
PEOPLE OF THE PHILIPPINES, petitioner, vs. LIBERTAD LAGON and HON. JUDGE ISIDRO O. BARRIOS, AS PRESIDING JUDGE OF THE CITY COURT OF ROXAS CITY, respondents.
FACTS
On July 7, 1976, an Information was filed with the City Court of Roxas City charging Libertad Lagon with estafa under Article 315(2)(d) of the Revised Penal Code for issuing a bouncing check in April 1975. The prosecution began presenting evidence. However, on December 2, 1976, the City Court dismissed the case without prejudice, holding it lacked jurisdiction. The court reasoned that while the offense at the time of its commission in April 1975 was within its jurisdiction, the penalty for the crime had been increased by Presidential Decree No. 818, effective October 22, 1975. This increased penalty, applicable at the time the Information was filed in July 1976, was beyond the City Court’s jurisdictional limit.
The People, through the City Fiscal, filed a Petition for Review, arguing the City Court retained jurisdiction. The Office of the Solicitor General, consulted on the matter, concurred with the petitioner’s position and requested the petition be given due course.
ISSUE
Whether the City Court of Roxas City correctly dismissed the criminal case for lack of jurisdiction based on the penalty in force at the time of the filing of the Information.
RULING
The Supreme Court denied the petition and affirmed the City Court’s dismissal order. The Court held that the fundamental rule is that the jurisdiction of a court in criminal cases is determined by the penalty prescribed by law at the time of the institution of the criminal action, not at the time of the commission of the offense. At the time the crime was committed in April 1975, the imposable penalty was within the jurisdictional limit of the City Court. However, when the Information was filed in July 1976, P.D. No. 818 had already taken effect, raising the penalty to prision mayor in its medium period. This penalty exceeded the maximum (prision correccional or six years) that a city court could impose under the Judiciary Act.
The Court clarified that this rule on jurisdiction does not violate the prohibition against the retroactive application of penal laws under Article 22 of the Revised Penal Code. Jurisdiction pertains to the court’s authority to hear a case, which is determined by the allegations in the information and the penalty imposable under the statute in effect when the case is filed. It does not dictate the actual penalty to be imposed after trial. If the case is refiled in the proper Regional Trial Court (RTC), that court would have jurisdiction to try it. However, in imposing judgment, the RTC must apply the more favorable penalty under the law in force at the time of the offense’s commission, as required by Article 22. The RTC does not lose jurisdiction simply because the penalty ultimately applicable is one originally within the City Court’s range.