G.R. No. 48974; March 20, 1944
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. BANAAG LINATOC and GERARDO LINATOC, defendants-appellees.

FACTS

The Chief of Police of Calamba, Laguna, filed a complaint on November 11, 1942, in the justice of the peace court against Banaag Linatoc and Gerardo Linatoc. The complaint accused them of “Slight Physical Injuries with Threats to Kill,” alleging that on or about November 6, 1942, in the Calamba public market, the accused, conspiring together, willfully assaulted Suzana Galvez by holding her arm, pushing and hitting her with a fist blow, causing injuries requiring medical attendance for seven days and incapacitating her for the same period. The complaint also alleged the aggravating circumstance of superior strength due to sex. The accused pleaded not guilty but were found guilty by the justice of the peace court of slight physical injuries with the aggravating circumstance of abuse of superior strength and were sentenced to twenty-one days of arresto menor and to indemnify the offended party. The accused appealed to the Court of First Instance. The Court of First Instance, upon motion of the accused’s counsel, dismissed the case without prejudice. It held that the complaint charged the complex crimes of slight physical injuries with grave threats, and since the penalty for the more serious crime (grave threats) was beyond the jurisdiction of the justice of the peace court, the Court of First Instance did not acquire appellate jurisdiction. The fiscal appealed this order of dismissal to the Supreme Court.

ISSUE

Whether the Court of First Instance correctly dismissed the case on appeal on the ground that the complaint charged a complex crime beyond the jurisdiction of the justice of the peace court, thereby depriving the Court of First Instance of appellate jurisdiction.

RULING

No. The Supreme Court reversed the order of dismissal and remanded the case to the Court of First Instance for further proceedings. The Court held that the complaint charged two distinct crimes: slight physical injuries (a light offense) and threats to kill (alleged to be the less grave offense of grave threats under Article 282 of the Revised Penal Code). The justice of the peace court had undoubted jurisdiction to try and decide the light offense of slight physical injuries. However, it had no jurisdiction over the less grave offense of grave threats. The complaint did not charge a complex crime under Article 48 of the Revised Penal Code, as amended, because: (1) slight physical injuries is a light offense, and the article applies only when a single act constitutes two or more “grave or less grave felonies”; and (2) the act causing slight physical injuries did not itself constitute the crime of grave threats, nor was one offense a necessary means for committing the other. Therefore, the justice of the peace court should have ignored the charge of threats to kill as beyond its jurisdiction. Consequently, the Court of First Instance, on appeal, acquired jurisdiction to try and decide the case concerning slight physical injuries and should ignore the charge of threats to kill unless a proper separate information for that offense is filed.