GR L 17621; (August, 1961) (Digest)
G.R. No. L-17621; August 31, 1961
Tomas Mallorca, petitioner-appellee, vs. Nicolas C. Adolfo, Justice of the Peace of Subic, Zambales, and Zacarias V. Mendoza, Chief of Police and Jail Warden of the Municipality of Subic, Zambales, respondent-appellants.
FACTS
A complaint was filed on August 24, 1960, in the Justice of the Peace Court of Subic, Zambales, charging Tomas Mallorca and two others with theft of property belonging to the United States. The alleged crime was committed “on or about the 18th day of August, 1960, in the U.S. Naval Base, Subic Bay, Subic, Zambales.” Based on this complaint, the Justice of the Peace of Subic issued a warrant of arrest, and Mallorca was taken into custody by the Chief of Police.
Mallorca filed a petition for a writ of habeas corpus before the Court of First Instance, seeking his release. He argued that the Justice of the Peace Court of Subic lacked jurisdiction because the locus criminis, the U.S. Naval Base area, was outside its territorial jurisdiction. The Court of First Instance, after hearing, found that the alleged crime was committed within the territorial jurisdiction of the Justice of the Peace Court of Olongapo and ordered Mallorca’s release. The Provincial Fiscal appealed this decision to the Supreme Court.
ISSUE
The core issue is whether the Justice of the Peace Court of Subic had jurisdiction to issue the warrant of arrest for a crime allegedly committed within the U.S. Naval Base area, or if jurisdiction properly pertained to the Justice of the Peace Court of Olongapo.
RULING
The Supreme Court affirmed the decision of the Court of First Instance, ruling that the Justice of the Peace of Subic acted without jurisdiction. The legal logic hinges on the application of Article 69 of the Judiciary Act (Republic Act No. 206, as amended). The prosecution contended that since Olongapo was constituted as a separate municipality only on December 7, 1959, and the crime was allegedly committed in a part of the Naval Base outside Olongapo’s new municipal boundaries, jurisdiction should remain with Subic. However, the Court found it undisputed that since 1947—long before Olongapo’s separation from Subic—the Justice of the Peace of Olongapo had already exercised criminal jurisdiction over the entire territory of the U.S. Naval Base.
Article 69 provides that when a new political division is formed, the justice of the peace previously exercising jurisdiction over a territory should continue to do so unless the President designates otherwise. Since no contrary presidential designation had been made by 1960 when the crime was committed, the Justice of the Peace of Olongapo remained the judicial officer with jurisdiction over offenses occurring within the Naval Base area. Consequently, the warrant of arrest and commitment order issued by the Justice of the Peace of Subic were null and void for lack of jurisdiction. The grant of the writ of habeas corpus was proper, but the ruling was without prejudice to the refiling of the complaint in the correct court, the Justice of the Peace Court of Olongapo.