G.R. No. L-15014. April 29, 1961.
PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. VICTORIANO VILLANUEVA, defendant-appellee.

FACTS

Victoriano Villanueva was charged in the Justice of the Peace Court of Batangas with the complex crime of serious and less serious physical injuries with damage to property amounting to P2,636.00 through reckless imprudence. After Villanueva pleaded not guilty, the private prosecutor filed a memorandum challenging the court’s jurisdiction. The memorandum argued that the imposable fine for the damage, separate from the penalties for the physical injuries, exceeded the court’s jurisdictional limit. Consequently, the justice of the peace court issued an order on November 24, 1958, declaring itself without jurisdiction and forwarding the case to the Court of First Instance (CFI).
The provincial fiscal filed a similar information in the CFI. Before arraignment, the defense moved to quash, contending that the CFI also lacked jurisdiction over the complex crime. The CFI, in an order dated January 21, 1959, agreed with the defense. It reasoned that the penalty for the more serious offense of physical injuries through reckless imprudence was only arresto mayor in its minimum and medium periods. Even when applied in its maximum degree for the complex crime, the penalty would allegedly remain within the jurisdiction of the justice of the peace court. The CFI thus ordered the case returned to the inferior court. The provincial fiscal appealed this order to the Supreme Court.

ISSUE

Whether the Court of First Instance or the Justice of the Peace Court has jurisdiction to try the complex crime of serious and less serious physical injuries with damage to property through reckless imprudence, where the damage amounts to P2,636.00.

RULING

The Supreme Court reversed the CFI order and held that jurisdiction lies with the Court of First Instance. The Court applied the rule established in Angeles vs. Jose, which interprets Article 365, paragraph 3 of the Revised Penal Code. This provision means that if reckless imprudence results only in damage to property, the fine shall be based on the amount of damage. However, if the same act causes both physical injuries and property damage, an additional penalty for the injuries is imposed on top of the fine for the damage. The resulting offense is a single, indivisible complex crime of physical injuries and damage to property.
The legal logic is clear and avoids absurdity. Since the damage to property alone (P2,636.00) would necessitate a fine of no less than that amount, which is beyond the jurisdictional limit of the justice of the peace court, jurisdiction for that component rests with the CFI. It would be illogical to hold that the graver offense, which combines physical injuries with such property damage, would fall under the jurisdiction of an inferior court. The presumption is against absurd interpretations, and the apportionment of criminal jurisdiction is based on the principle that more serious crimes are triable by CFIs.
Furthermore, practical considerations support this ruling. If the case were tried in the justice of the peace court and the prosecution subsequently failed to prove the physical injuries but only established the property damage, the inferior court would find itself without jurisdiction to impose the mandatory fine, creating an untenable situation. To prevent this jurisdictional dilemma, the case must originate in the CFI, which has jurisdiction over all components of the complex charge. The records were remanded to the CFI for trial.