G.R. No. L-23848; October 31, 1967
PORFIRIO RILLORAZA, petitioner-appellee, vs. JUDGE PEDRO ARCIAGA, ETC., ET AL., respondents. EULALIA BANAYAT, respondent-appellant.

FACTS

On June 18, 1963, respondent Eulalia Banayat filed a criminal complaint for direct assault upon a person in authority (Article 148, Revised Penal Code) against petitioner Porfirio Rilloraza in the Municipal Court of San Fernando, La Union. On February 7, 1964, petitioner moved to quash the complaint for lack of jurisdiction, which was denied. The municipal court commenced trial on the merits, and three prosecution witnesses testified. On June 3, 1964, petitioner filed a petition for certiorari and prohibition with the Court of First Instance (CFI) of La Union. On October 8, 1964, the CFI declared the municipal court proceedings null and void, ordered the judge to desist from continuing the hearing, and directed the transmission of the case records to the Municipal Court of Naguilian, La Union, for preliminary investigation. Respondent Banayat appealed this CFI order.

ISSUE

Whether the Municipal Court of San Fernando, La Union, retained jurisdiction to try the criminal case for direct assault after the enactment of Republic Act No. 3828 on June 22, 1963, which amended the jurisdictional provisions of the Judiciary Act of 1948, considering that the complaint was filed on June 18, 1963, while Republic Act No. 2613 was still in effect.

RULING

The Supreme Court reversed the CFI order and reinstated the jurisdiction of the Municipal Court of San Fernando, La Union. The Court held:
1. Jurisdiction is determined at the time of filing. The jurisdiction of a court to try a criminal case is determined by the law in force at the time the action is instituted. The complaint was filed on June 18, 1963, when Republic Act No. 2613 was effective. Under this law, the justice of the peace court (municipal court) in provincial capitals had jurisdiction to try offenses where the penalty did not exceed prision correccional (imprisonment not exceeding six years) or a fine not exceeding three thousand pesos, or both. The charge of direct assault under Article 148 of the Revised Penal Code carries a penalty within these limits, so the Municipal Court of San Fernando, La Union, initially had jurisdiction.
2. Jurisdiction, once acquired, is not ousted by a subsequent change in law. The passage of Republic Act No. 3828 on June 22, 1963—which limited the jurisdiction of municipal courts in provincial capitals to offenses “committed within their respective jurisdictions”—did not divest the Municipal Court of San Fernando of jurisdiction already acquired. Jurisdiction, once attached, continues until the case is finally determined. A subsequent statute removing jurisdiction will not operate to oust jurisdiction already attached unless express prohibitory words are used. Republic Act No. 3828 contains no such express prohibitory language.
3. Republic Act No. 3828 is not a penal statute. The argument that Republic Act No. 3828 should be given retroactive effect as a penal law favorable to the accused is untenable. The law merely delineates court jurisdiction and does not define crimes or prescribe penalties. Penal statutes impose punishments for violations; jurisdictional statutes do not. Therefore, Republic Act No. 3828 cannot be applied retroactively.
The Supreme Court directed the Municipal Court of San Fernando, La Union, to continue with Criminal Case No. 4987 until its final determination. Costs were imposed on the petitioner.