GR L 12915; (July, 1959) (Digest)
G.R. No. L-12915. July 28, 1959.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. JOSE FULE, defendant-appellee.
FACTS
On June 18, 1957, the Provincial Fiscal of Laguna filed an information for serious oral defamation against Jose Fule with the office of the deputy clerk of court of the second branch of the Court of First Instance of Laguna in San Pablo City. The alleged offense was committed on December 20, 1956. On June 20, 1957, the information was received in the office of the deputy clerk of court of the third branch of the same court, as per Administrative Order No. 149 (1955) of the Secretary of Justice, which assigned cases from the Municipality of Alaminos (where the offense occurred) to the third branch. The accused filed a motion to quash on July 27, 1957, arguing that the criminal action had prescribed because the information was filed with the third branch on June 20, 1957, which was beyond the six-month prescriptive period under Article 90 of the Revised Penal Code (the last day to file being June 18, 1957). The Provincial Fiscal opposed, contending the information was filed on June 18, 1957. The trial court (Judge Cecilia Muñoz Palma) sustained the motion to quash and dismissed the information, reasoning that each branch of the court is separate and independent, with its own deputy clerk, and thus filing with the second branch did not constitute filing with the third branch. The prosecution’s motion for reconsideration was denied, leading to this appeal.
ISSUE
Whether the filing of the information with the office of the deputy clerk of court of the second branch of the Court of First Instance of Laguna on June 18, 1957, interrupted the running of the prescriptive period for the offense, notwithstanding that the case was cognizable by the third branch.
RULING
The Supreme Court reversed the trial court’s order and remanded the case for further proceedings. The Court held that the filing of the information with the deputy clerk of court of the second branch on June 18, 1957, was timely and interrupted the prescriptive period. The Court rejected the trial court’s theory that each branch is a separate and independent court. Citing Norberto Lumpay, et al. vs. Hon. Segundo Moscoso and Section 57 of Republic Act No. 296 (the Judiciary Act), the Court ruled that there is only one Court of First Instance of Laguna, and its branches are not distinct courts but divisions of a single court with coordinate and equal jurisdiction. Jurisdiction is vested in the court as a whole, not in individual judges or branches. The administrative apportionment of cases among branches, as per the Secretary of Justice’s order, is for convenience and coordination, not a grant or limitation of jurisdiction. Therefore, filing the information with any branch constitutes filing with the Court of First Instance of Laguna. Since the information was filed within the prescriptive period on June 18, 1957, the trial court erred in quashing it on grounds of prescription.