GR L 12703; (March, 1959) (Digest)
G.R. No. L-12703; March 25, 1959
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. MAXIMA ORPILLA-MOLINA, ET AL., defendants-appellees.
FACTS
The defendants were charged before the Court of First Instance of Cagayan with indirect contempt of the Justice of the Peace Court of Alcala, Cagayan. The charge stemmed from their unlawful re-entry into land from which they had been previously ejected by the sheriff pursuant to a final decision of said inferior court. The defendants challenged the court’s jurisdiction, arguing that the penalty for such contempt under Section 6 of the Rules of Court—a fine not exceeding P100 or imprisonment for not more than one month or both—placed the offense beyond the original jurisdiction of courts of first instance. The trial court sustained the defendants’ contention and dismissed the complaint.
ISSUE
Whether the Court of First Instance has jurisdiction over proceedings for indirect contempt committed against a Justice of the Peace Court, notwithstanding that the prescribed penalty falls within the general original jurisdiction of inferior courts under the Judiciary Act.
RULING
Yes. The Supreme Court reversed the trial court’s order of dismissal. While Republic Act No. 296 (The Judiciary Act of 1948) generally assigns to justice of the peace courts jurisdiction over criminal offenses punishable by imprisonment not exceeding six months or a fine not exceeding P200 or both, this case constitutes an exception. Under Section 4 of Rule 64, proceedings for contempt committed against a justice of the peace court “may be instituted” either in the court of first instance or in such justice of the peace court. Rule 64 is as much a law as Republic Act No. 296, and both should be construed together, making the former an exception to the latter to avoid repeal. Furthermore, this contempt was essentially civil in nature (aimed at benefiting the adverse party), which reasonably distinguishes it from ordinary criminal cases allocated to inferior courts. Adopting the appellees’ viewpoint would also lead to the absurd result of depriving courts of first instance of jurisdiction to punish direct contempts against themselves, impairing their inherent power of self-preservation and ability to enforce obedience to their orders. The record was remanded to the trial court for further proceedings.