G.R. No. L-47961; April 30, 1941
EL PUEBLO DE FILIPINAS, querellante y apelado, vs. MANUEL CONCORDIA, acusado y apelante.

FACTS

The accused, Manuel Concordia, was charged in the Court of First Instance of Rizal with the crime of damage to property through reckless imprudence. He was convicted under paragraph 4 of Article 365 of the Revised Penal Code and sentenced to pay a fine of P20, indemnify the offended party P81, with corresponding subsidiary imprisonment in case of insolvency for both amounts, plus costs. The accused appealed the conviction to the Court of Appeals, which certified the case to the Supreme Court because the jurisdiction of the trial court was disputed both in the first instance and on appeal. The proven facts, as found by the trial court, are: on the morning of August 5, 1937, a car (No. 1-8639) was traveling along Taft Avenue towards Parañaque from Manila. Upon reaching the “Oregon Bar” in Pasay, Rizal, its driver signaled and turned right to head back towards Manila. Before completing the turn, the left rear of this car was violently struck by the front of car No. 1-10852, which was being driven by the appellant. As a result of the collision, car No. 1-8639 suffered damages amounting to P81.

ISSUE

1. Whether the facts alleged in the complaint constitute a crime or merely civil liability.
2. Whether the Court of First Instance of Rizal had jurisdiction over the case.

RULING

1. On the Nature of the Liability: The Supreme Court held that the appellant’s contention that the facts alleged imply, at most, civil liability only is erroneous. The complaint, by its allegations, describes the offense defined and punished under paragraph 3 of Article 365 of the Revised Penal Code, which imposes a fine equivalent to one to three times the value of the damage caused, but in no case less than P25. The Court clarified that the appellant mistakenly insinuated the applicable provision was Article 329(3) of the Revised Penal Code, as amended by Act No. 3999 , and incorrectly argued that paragraph 3 of Article 365 was inapplicable, when it was precisely the provision under which the complaint was filed.
2. On Jurisdiction: The Supreme Court ruled that the crime charged falls within the jurisdiction of the Court of First Instance of Rizal. The imposable fine under paragraph 3 of Article 365 could be P243 (equivalent to triple the P81 damage), and a fine of this amount, by its quantification, is beyond the jurisdiction and competence of the justice of the peace court of Pasay, the place where the crime was committed.
The Court further found the appellant’s other assignments of error unmeritorious, as the evidence satisfactorily established that the appellant was driving the car that caused the accident due to his carelessness and negligence, thus holding him criminally liable was correct.
However, the trial court erred in applying paragraph 4 of Article 365. The proven facts constitute the offense defined under paragraph 3 of the same article. Therefore, the appealed decision was modified.
DISPOSITIVE PORTION:
The appealed judgment is modified in the sense that the appellant must pay a fine of P243, instead of only P20, and is affirmed in all other respects, with the costs of this instance charged to the appellant.