G.R. No. L-46934 April 15, 1988
ALFREDO CUYOS y TULOR, petitioner, vs. HON. NICOLAS P. GARCIA, Presiding Judge, Municipal Court, San Fernando, Pampanga and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Alfredo Cuyos was charged before the Municipal Court of San Fernando, Pampanga, with the complex crime of homicide with multiple serious physical injuries and damage to property through reckless imprudence. The amended complaint alleged that his truck collided with a Volkswagen, resulting in one death, injuries to four persons, and property damage amounting to P18,000.00. After pleading not guilty, Cuyos filed a Motion to Remand the Case to the Court of First Instance for trial, arguing that the Municipal Court lacked jurisdiction.
Petitioner’s jurisdictional challenge was based on the penalty structure under Article 365 of the Revised Penal Code. He contended that for damage to property through reckless imprudence, the imposable fine ranges from the amount of damage to three times such amount. With alleged damages of P18,000.00, the maximum fine could reach P54,000.00. Since the Municipal Court, under the then applicable Judiciary Act, had jurisdiction only over offenses punishable by a fine not exceeding P6,000.00, petitioner asserted that the case fell within the exclusive original jurisdiction of the Court of First Instance. The respondent Municipal Judge denied the motion, prompting this Petition for Certiorari.

ISSUE

Whether the respondent Municipal Court of San Fernando, Pampanga, had jurisdiction to try the criminal case for reckless imprudence resulting in homicide, multiple serious physical injuries, and damage to property.

RULING

The Supreme Court ruled that the Municipal Court had no jurisdiction. The legal logic centers on determining the proper penalty for the complex crime to ascertain jurisdictional competence. The case involves a single act of reckless imprudence resulting in multiple consequences—a homicide, serious physical injuries, and damage to property. Under Article 48 of the Revised Penal Code, for a complex crime, the penalty for the most serious offense is imposed in its maximum period. While the most serious consequence is homicide, the Court, following established precedent, held that for jurisdictional purposes in cases of reckless imprudence producing both physical injuries and damage to property, the court’s jurisdiction is determined by the fine imposable for the damage to property, not solely by the penalty for the physical injuries or homicide.
Applying Article 365, the fine for the damage to property could range from P18,000.00 to P54,000.00. This maximum possible fine of P54,000.00 far exceeded the Municipal Court’s jurisdictional limit of a P6,000.00 fine under the Judiciary Act. Consequently, the case was beyond the Municipal Court’s jurisdiction and properly pertained to the Court of First Instance (now Regional Trial Court). The Court made the Temporary Restraining Order permanent, set aside the Municipal Court’s order, and directed the filing of a new information in the Regional Trial Court.