G.R. No. L-37446 May 31, 1974
RENO ARCAYA and EMMANUEL CEBALLOS, petitioners, vs. The Honorable JUDGE VICTORINO C. TELERON, as Judge, Branch III, Court of First Instance of Bohol; Hon. JUDGE, Municipality of Tubigon, Bohol; Hon. CHIEF OF POLICE of Tubigon, Bohol; and Minor MARY CARLYN RELAMPAGOS, thru her legal guardian, DR. MANUEL RELAMPAGOS, respondents.

FACTS

On March 1, 1971, a jeep owned by the Philippine National Bank and allegedly driven by petitioner Emmanuel Ceballos, with petitioner Reno Arcaya having permitted its use, collided with another vehicle in Tubigon, Bohol. The incident caused injuries to passengers and property damage. The chief of police subsequently filed a single complaint charging both petitioners with “double less serious physical injuries, slight physical injuries and damage to property thru reckless imprudence.” Petitioners moved to quash this complaint, arguing improper joinder of three distinct offenses. In response, the prosecution filed two amended complaints, segregating the charge for slight physical injuries (a light felony) into a separate docket (Criminal Case No. 1397-A) from the complex crime of less serious physical injuries with damage to property.
Despite this amendment, petitioners pressed their motion to quash, adding the ground that the light felony of slight physical injuries had already prescribed. The municipal court denied the motion. Petitioners then elevated the matter via certiorari and prohibition to the Court of First Instance (CFI), which dismissed their petition. They subsequently filed the instant special civil actions with the Supreme Court, contending the municipal court never acquired jurisdiction due to the initial improper joinder and that it lacked jurisdiction over a prescribed offense.

ISSUE

Whether the municipal court acted without or in excess of jurisdiction or with grave abuse of discretion in denying the motion to quash the amended complaints.

RULING

The Supreme Court dismissed the petition. The Court clarified fundamental concepts of jurisdiction and the limited scope of certiorari. First, jurisdiction is conferred by law, not by the complaint. The complaint merely provides the occasion for a court to exercise its law-given jurisdiction. The Municipal Court of Tubigon indisputably had exclusive original jurisdiction over the light felony and authority to conduct a preliminary investigation for the complex crime, as provided by the Judiciary Law.
Second, the issue of prescription is not jurisdictional. Prescription is a defense to be raised and resolved by the court that has jurisdiction over the subject matter. The Court found the light felony had not prescribed. It was committed on March 1, 1971, and the original complaint was filed on April 27, 1971—within the 60-day prescriptive period for light felonies. The subsequent amendment and re-filing on July 9, 1971, did not reset the clock; the commencement of the criminal action interrupted the prescriptive period, and the amended complaint related back to the date of the original filing.
Since the municipal court had jurisdiction over both the subject matter and the persons of the accused, its order denying the motion to quash—however allegedly erroneous—was an exercise of its jurisdiction, not an excess thereof. Any error in its ruling is correctible by appeal after trial on the merits, not by the extraordinary writ of certiorari, which is reserved for correcting jurisdictional errors. The petition, based on a misapprehension of these principles, was without merit.