G.R. No. L-2705

FACTS:
The defendant-appellant, Alberto Gonzalez, was a justice of the peace in Kaibiran, Leyte. In his official capacity, he tried, convicted, and sentenced Ambrosio de los Reyes to four months of imprisonment for the crime of estafa. Subsequently, a criminal prosecution for “arrogacion de atribuciones” (usurpation of judicial functions) was initiated against Gonzalez. The complaint and the judgment of conviction from the lower court did not specify the article of the Penal Code under which he was charged and condemned, but it was assumed to be Article 194.

ISSUE:
Whether the defendant, a justice of the peace, can be held criminally liable for usurpation of judicial functions under Article 194 of the Penal Code for an error in the interpretation of the law regarding his jurisdiction.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted the defendant. The Court held that the defendant was lawfully exercising the judicial functions conferred upon him by his office as a justice of the peace. His act of trying and sentencing the accused for estafa, even if based on a mistaken interpretation of the law concerning the jurisdictional limit of penalties (i.e., believing he had jurisdiction as long as the penalty imposed was less than six months), constituted an error committed by a judicial officer in the exercise of his duties. Such an error does not amount to the crime of usurpation of judicial functions under Article 194 of the Penal Code. The case is governed by the precedent in United States vs. Florentino Rallos, where it was ruled that a public officer exercising conferred judicial functions does not arrogate such functions to himself, and errors made in the exercise of those functions are not punishable under said article.