G.R. No. L-27790 July 31, 1969
SOFRONIO ALCANTARA, petitioner-appellant, vs. THE HONORABLE MARCELO VALDEHUEZA, in his capacity as Judge of Branch 2 of the City Court of Cagayan de Oro, and FRANCISCO RABANES in his capacity as the prosecuting officer in Criminal Case No. 13814 now pending in Branch 2 of the City Court of Cagayan de Oro, respondents-appellees.

FACTS

Petitioner Sofronio Alcantara filed a motion to quash the information in Criminal Case No. 13814 for theft, pending in the City Court of Cagayan de Oro, on the ground of lack of jurisdiction. The articles stolen had a total value of P438.20. The City Court denied his motion. Alcantara then filed a petition for prohibition with the Court of First Instance of Misamis Oriental, which was also denied. He subsequently appealed directly to the Supreme Court. Alcantara argued that the City Court’s jurisdiction over theft cases is strictly limited by Section 87(b)(3) of the Judiciary Act of 1948, as amended, which grants original jurisdiction over larceny, embezzlement, and estafa only where the amount involved does not exceed two hundred pesos.

ISSUE

Whether the City Court of Cagayan de Oro has jurisdiction to try a criminal case for theft where the value of the stolen property is P438.20, which exceeds the P200 limit specified in Section 87(b)(3) of the Judiciary Act of 1948, as amended.

RULING

Yes, the City Court of Cagayan de Oro has jurisdiction. The Supreme Court affirmed the order of the Court of First Instance denying the petition for prohibition. The Court held that while Section 87(b)(3) provides a specific jurisdictional limit for certain crimes, the penultimate paragraph of Section 87, as amended, expands the jurisdiction of city court judges and municipal judges in provincial capitals. This paragraph grants them “like jurisdiction as the Court of First Instance to try parties charged with an offense committed within their respective jurisdictions, in which the penalty provided by law does not exceed prision correccional or imprisonment for not more than six years or fine not exceeding six thousand pesos or both.” The penalty for theft of property valued over P200 but not exceeding P6,000, under Article 309(3) of the Revised Penal Code, is prision correccional in its medium and maximum periods, which falls within the jurisdictional grant of the penultimate paragraph. Therefore, the City Court holds jurisdiction concurrent with the Court of First Instance for such an offense. This interpretation is supported by Congress’s clear intent to expand the jurisdiction of these courts, as further evidenced by the last paragraph of Section 87, which provides for the trial and appeal of cases filed under the penultimate paragraph. Costs were imposed against the petitioner.