G.R. No. L-47482 July 21, 1978
ANGELITO TAN, ALEX VILLAVERDE, JOSELITO TAN and GEORGE LELIS, petitioners, vs. PEOPLE OF THE PHILIPPINES, HON. DELIA P. MEDINA, as Presiding Judge of Branch I, Court of First Instance of Quezon; JOSE J. PARENTELA, as the Municipal Judge of Sariaya, Quezon; PROVINCIAL FISCAL of Quezon; HILARION ABADEJOS, and ZENAIDA ABADEJOS, respondents.

FACTS

Petitioners were charged with estafa in the Municipal Court of Sariaya, Quezon, for failing to return a Zenith television set valued at P2,375 which they had allegedly undertaken to repair. After the prosecution presented its evidence, petitioners filed a demurrer to the evidence and later a motion to dismiss based on lack of jurisdiction, citing Section 87(b)(3) of the Judiciary Law, which grants municipal courts jurisdiction over estafa only if the amount involved does not exceed P200. The municipal judge denied the motion. Upon reconsideration, a different municipal judge granted the motion and elevated the case to the Court of First Instance (CFI). However, the provincial fiscal successfully moved for its return to the municipal court, arguing concurrent jurisdiction. Petitioners then filed a petition for certiorari, prohibition, and mandamus in the CFI, assailing the municipal court’s orders. The CFI dismissed the petition, ruling that the estafa case fell under the concurrent jurisdiction of both courts pursuant to Section 87(c) of the Judiciary Law, and remanded the case to the municipal court.

ISSUE

Does the Municipal Court of Sariaya, Quezon, have jurisdiction over an estafa case where the amount of fraud exceeds P200?

RULING

No. The Supreme Court reversed the CFI’s order and held that the municipal court lacked jurisdiction. The jurisdictional grant for estafa under Section 87(b)(3) of the Judiciary Law is explicit and amount-specific: municipal courts have original jurisdiction only when the amount involved does not exceed P200. Since the value of the television set was P2,375, the case fell beyond this limit. The Court clarified that for estafa, the jurisdictional criterion is the amount of the fraud, not the penalty prescribed by law. Consequently, such a case is within the original and exclusive jurisdiction of the Court of First Instance under Section 44(f) of the same law. The CFI erred in applying Section 87(c), which grants jurisdiction over offenses with penalties of imprisonment not exceeding three years or a fine not exceeding P3,000, because estafa is specifically enumerated in paragraph (b). Under the principle of statutory construction, a special provision (Section 87(b)(3)) governs over a general one (Section 87(c)). Furthermore, the penultimate paragraph of Section 87, granting expanded jurisdiction to municipal judges in provincial capitals, was inapplicable as Sariaya is not a provincial capital. The proceedings in the municipal court could only be treated as a preliminary investigation. The record was ordered transmitted to the CFI for appropriate proceedings.