GR L 24191; (March, 1965) (Digest)
G.R. No. L-24191, March 31, 1965
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE ADOLFO Y RAYMUNDO, defendant-appellant.
FACTS
Jose Adolfo y Raymundo was charged in the Court of First Instance of Manila on July 30, 1963, with the offense of damage to property through reckless imprudence under Article 365 of the Revised Penal Code, arising from an accident that occurred on April 10, 1963. The information alleged the damage sustained by the offended party was P890.49. He was found guilty and sentenced to pay damages of P485.55 and a fine of P971.10. The accused appealed, questioning, among other things, the jurisdiction of the Court of First Instance. He argued that since the maximum penalty imposable under Article 365(3) is a fine not more than three times the value of the damage (which would be P2,671.47 based on the allegation), and pursuant to Section 87(c) of the Judiciary Act as amended by Republic Act 3828 (effective June 22, 1963), which grants municipal courts original jurisdiction over offenses punishable by a fine of not more than P3,000.00, the case fell within the original jurisdiction of the municipal court, not the Court of First Instance.
ISSUE
Whether the Court of First Instance of Manila had jurisdiction over the criminal case for damage to property through reckless imprudence, considering the amendatory law (Republic Act 3828) that took effect after the commission of the offense but before the institution of the action.
RULING
No. The Supreme Court set aside the decision of the lower court and dismissed the information. The jurisdiction of a court to try a criminal action is determined by the law in force at the time of the institution of the action, not by the law in force at the time of the commission of the offense. Since Republic Act 3828, which vested municipal courts with original jurisdiction over offenses punishable by a fine of not more than P3,000.00, was already in effect when the information was filed on July 30, 1963, and the maximum imposable fine for the offense (P2,671.47) was within that threshold, the case was cognizable by the municipal court. Consequently, the Court of First Instance lacked jurisdiction over the subject matter.