G.R. No. L-16478; August 31, 1961
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MODESTO MALABANAN Y ARANDIA, defendant-appellant.

FACTS

Modesto Malabanan was charged in the Court of First Instance (CFI) of Laguna with the complex crime of double serious physical injuries and damage to property through reckless imprudence. The information alleged that his negligent driving caused a collision, resulting in serious injuries to two individuals requiring long-term medical attendance and incapacitation, and property damage amounting to P3,000.00. After trial, the CFI found him guilty and imposed a fine of P8,000.00 with subsidiary imprisonment, while making no pronouncement on civil liability as the injured parties had reserved their right to file separate actions.
The appellant appealed to the Court of Appeals, which elevated the case to the Supreme Court, certifying that it raised a pure legal question regarding jurisdiction. Appellant contended that the CFI lacked jurisdiction, arguing that under the ruling in Lapuz v. Court of Appeals, the penalty for the more serious offense in the complex crime (multiple serious physical injuries) should govern jurisdiction. Since the penalty for that offense is arresto mayor in its medium to maximum periods, jurisdiction would properly lie with the Justice of the Peace Court, not the CFI.

ISSUE

Whether the Court of First Instance of Laguna had jurisdiction to try the complex crime of double serious physical injuries with damage to property through reckless imprudence.

RULING

Yes, the Court of First Instance correctly assumed jurisdiction. The Supreme Court rejected the appellant’s reliance on a strict application of Lapuz for determining jurisdiction in this context. While Article 48 of the Revised Penal Code governs the imposition of the penalty for the complex crime, jurisdiction is determined differently to avoid absurd and impractical results.
The Court held that jurisdiction must be ascertained by considering the fine imposable for the damage to property resulting from the reckless imprudence, not merely the penalty for the physical injuries. Since the alleged property damage was P3,000.00, the imposable fine under Article 365 could not be less than this amount, which falls within the exclusive original jurisdiction of the CFI. This interpretation, established in Angeles v. Jose, prevents the illogical scenario where a CFI would have jurisdiction over damage to property alone, but would lose it when the more serious complex crime including physical injuries is charged.
Furthermore, the Court, citing People v. Villanueva, emphasized the necessity of this rule to account for the possibility that the prosecution might fail to prove all components of the complex crime. If jurisdiction were vested in the inferior court based on the physical injuries and the prosecution later only proved the damage to property, that inferior court would lack jurisdiction to impose the requisite fine, creating an untenable procedural dilemma. Therefore, the CFI properly took cognizance of the case. The Supreme Court resolved the jurisdictional issue and remanded the case to the Court of Appeals for determination of the remaining factual assignments of error.