G.R. No. L-33757 March 29, 1982
Bayani Quinto and Danilo Enriquez, petitioners, vs. Hon. Onofre A. Villaluz, Presiding Judge, Circuit Criminal Court, Pasig, Rizal; and District State Prosecutor Cornelio M. Melendres, respondents.

FACTS

On June 15, 1971, Lamberto Alcantara was killed in Rosario, Cavite. Two separate criminal complaints for homicide were subsequently filed. The first was filed on June 16, 1971, in the Municipal Court of Rosario, Cavite, by the local chief of police against petitioner Bayani Quinto alone. After a preliminary examination by the mayor and a preliminary investigation by the municipal judge, the case was remanded to the Court of First Instance (CFI) of Cavite on June 29, 1971, and docketed as Criminal Case No. TM-101. The second complaint was filed directly with the Circuit Criminal Court (CCC) of Pasig, Rizal, on June 18, 1971, by a PC Lieutenant against three accused: Bayani Quinto, Danilo Enriquez, and Valeriano Reyes.
Petitioners Quinto and Enriquez moved for the CCC to reconsider its order for a preliminary investigation, arguing the CFI of Cavite had already acquired exclusive jurisdiction over the case. Meanwhile, the victim’s widow filed a motion in the Cavite CFI to transfer its case to the CCC. The assistant provincial fiscal assigned interposed no objection, leading to the transfer of the Cavite court’s records to the CCC on July 15, 1971. Petitioners then filed this certiorari petition to restrain the CCC from proceeding.

ISSUE

Whether the Circuit Criminal Court of Pasig, Rizal, validly acquired jurisdiction over the criminal case despite the prior filing and remand of a related complaint to the Court of First Instance of Cavite.

RULING

The Supreme Court dismissed the petition, upholding the Circuit Criminal Court’s jurisdiction. The legal logic is anchored on the principle of concurrent jurisdiction and the stage at which a court acquires jurisdiction over a criminal case. Republic Act No. 5179 conferred upon circuit criminal courts concurrent jurisdiction with courts of first instance over specified crimes. Jurisdiction is acquired by a court upon the filing of the complaint or information. Since no information had yet been filed by the fiscal in the Cavite CFI case—only a complaint had been filed and the record remanded for further prosecutorial action—that court had not acquired exclusive jurisdiction. The filing of the complaint directly with the CCC on June 18, 1971, prior to the remand to the CFI on June 29, was therefore valid.
Furthermore, the fiscal possesses the discretion to choose the forum when filing an information for crimes within this concurrent jurisdiction, as affirmed in Salcedo vs. Suarez. The transfer of the record from the Cavite CFI to the CCC, facilitated by the fiscal’s lack of objection, was a proper exercise of this prosecutorial prerogative. Consolidating the cases in the CCC also promotes judicial efficiency, as it avoids a multiplicity of suits by trying all three accused together, rather than trying petitioner Quinto separately in Cavite.