G.R. No. L-4 & G.R. No. L-19; September 4, 1945
Angel Cruz y Encarnacion, petitioner-appellant, vs. Guillermo Cabrera, Judge of Municipal Court of Manila, respondent-appellee.

FACTS

1. Petitioner Angel Cruz was accused on May 17, 1945, in the Municipal Court of Manila of qualified theft of eight cases of storage batteries valued at P40. He had been released on bail since May 15, 1945.
2. At trial, a prosecution witness testified the batteries’ value “could have been P240,” not the P40 alleged in the information. The batteries were not produced in court.
3. After the prosecution rested, Cruz moved to quash the information for lack of jurisdiction, arguing the municipal court had no jurisdiction over qualified theft involving P240. The respondent judge denied the motion. Cruz declined to present evidence.
4. On May 31, 1945, Cruz filed an omnibus motion containing all objections, which was also denied.
5. On June 4, 1945, the respondent judge issued an order for Cruz to appear on June 9, 1945, for promulgation of sentence. Cruz claims he never received this order.
6. On June 8, 1945, Cruz filed a petition for certiorari and a writ of preliminary injunction in the Court of First Instance (CFI) of Manila against the respondent judge.
7. On June 9, 1945, the respondent judge issued an order for Cruz’s arrest due to his change of residence. On June 12, 1945, he issued a bench warrant for Cruz’s arrest for failure to appear on June 9. Cruz was arrested on June 19, 1945.
8. On June 15, 1945, Judge Mamerto Roxas of the CFI of Manila denied the motion for a preliminary injunction and dismissed the certiorari petition. Cruz’s motion for reconsideration was denied, and he filed a notice of appeal on June 26, 1945.
9. On June 19, 1945, the judgment of conviction was promulgated, finding Cruz guilty of qualified theft of property valued at P40 as alleged in the information, notwithstanding the witness’s testimony about a possible higher value. On June 20, 1945, Cruz filed a petition for a writ of habeas corpus in the CFI of Manila, alleging his detention under the bench warrant was unlawful while the certiorari proceedings were pending.
10. On June 22, 1945, the CFI of Manila denied the habeas corpus petition. Cruz filed a notice of appeal the same day.
11. On June 26, 1945, Cruz filed a notice of appeal to the CFI of Manila from the municipal court’s judgment of conviction (sentencing him to six months and one day of prision correccional) and filed an appeal bond. This appealed case was docketed as Criminal Case No. 70893.

ISSUE

1. Whether the Municipal Court of Manila has jurisdiction to try cases of qualified theft when the value of the property alleged in the information is P40 (or does not exceed P200).
2. Whether the municipal court lost jurisdiction because a prosecution witness testified the property’s value “could have been P240.”
3. Whether the bench warrant issued for Cruz’s arrest for failure to appear at the promulgation of sentence was illegal, making his detention unlawful for habeas corpus purposes.

RULING

1. On Jurisdiction over Qualified Theft: Yes. The Municipal Court of Manila has jurisdiction to try theft cases, including qualified theft, as long as the value of the property involved does not exceed P200, pursuant to Section 2648 of the Administrative Code as amended by Commonwealth Act No. 361. Jurisdiction is determined by the value of the property stolen as alleged in the information, not by the higher penalty prescribed for the qualified offense. This doctrine is settled in prior cases (People vs. De Leon, People vs. Kaw Liong, et al.).
2. On the Effect of Testimony Suggesting a Higher Value: No. The municipal court did not lose jurisdiction. The respondent judge, in convicting Cruz, impliedly and evidently found the value of the stolen property to be P40 as alleged in the information. The court is not bound by a witness’s testimony on value and may use its discretion in assessing the facts. Such a finding of fact is more properly reviewable on appeal, not in a certiorari proceeding.
3. On the Legality of the Bench Warrant and Habeas Corpus: The bench warrant was legally issued under the authority of Section 2469 of the Revised Administrative Code. Furthermore, the issue in the habeas corpus case has become moot due to the subsequent promulgation of the judgment of conviction and Cruz’s appeal from that judgment. Habeas corpus cannot be invoked to correct alleged errors of a trial court that had jurisdiction over the person and subject matter, especially when the right of appeal exists and has been exercised. The writ’s purpose is to determine the legality of detention, not to review errors that do not render a judgment void.
DISPOSITIVE:
The judgments appealed from, which dismissed the petitions for certiorari and habeas corpus, are affirmed. Costs are awarded against petitioner-appellant in both instances.