G.R. No. L-23000 November 4, 1967
MATEO J. PABULARIO, petitioner-appellee, vs. THE HONORABLE POMPEYO L. PALARCA, City Judge of Iligan City, respondent-appellant.

FACTS

Petitioner-appellee Mateo J. Pabulario was the accused in Criminal Case No. 1509-AF before the Municipal Court of Iligan City, presided over by respondent-appellant Judge Pompeyo L. Palarca. The information alleged that Pabulario, while driving a truck in a negligent manner, caused it to bump a passenger jeep, resulting in property damage of P397.00 and slight physical injuries to two passengers. The information charged a violation of Article 365 in relation to Article 266 of the Revised Penal Code. Pabulario filed a motion to quash the information, contending it charged more than one offense: damage to property through reckless imprudence and multiple slight physical injuries through reckless imprudence. Respondent Judge denied the motion to quash and subsequent motions for reconsideration. Pabulario then filed a petition for certiorari (Case No. 582) with the Court of First Instance of Lanao del Norte, arguing that the municipal court lacked jurisdiction over the criminal case and that the judge’s orders were null and void. The Court of First Instance granted the writ of certiorari, sustaining Pabulario’s contention. Respondent Judge appealed this decision to the Supreme Court.

ISSUE

Whether the Municipal Court of Iligan City lacked jurisdiction to hear Criminal Case No. 1509-AF on the ground that the information charged more than one offense.

RULING

The Supreme Court reversed the decision of the Court of First Instance and dismissed the petition for certiorari. The Court held that the municipal court had jurisdiction. The information did not charge two separate offenses to be complexed; rather, it alleged a single quasi-offense of reckless imprudence resulting in multiple consequences (damage to property and slight physical injuries). Following the doctrine in People vs. Cano, the Court ruled that criminal negligence or imprudence is treated as a single quasi-offense, and the effects or consequences of the negligent act are not the principal factors but merely determine the penalty. Even assuming arguendo that two offenses were charged, both offenses (damage to property amounting to P397.00 and multiple slight physical injuries, both through reckless negligence) were within the jurisdiction of the municipal court. Furthermore, the orders denying the motion to quash, even if potentially erroneous, were not null and void. The proper procedure would have been to proceed with the trial on the merits.