GR L 64050; (September, 1984) (Digest)
G.R. No. L-64050 September 12, 1984
PEOPLE OF THE PHILIPPINES (LUZ MARQUEZ), petitioner, vs. COURT OF FIRST INSTANCE OF ORIENTAL MINDORO, BRANCH I and MATILDE FESALVO, respondents.
FACTS
Luz Marquez filed a complaint for Grave Slander against Matilde Fesalvo with the Municipal Court of Calapan, Oriental Mindoro. After trial, the municipal court found Fesalvo guilty of the lesser offense of slight oral defamation on January 15, 1982, and imposed a fine. Fesalvo appealed this decision to the Court of First Instance (CFI) of Oriental Mindoro. The CFI, acting on the appeal, reversed the municipal court’s judgment and acquitted Fesalvo on August 31, 1982.
The petitioner, through the Solicitor General, filed a motion for reconsideration, challenging the CFI’s decision on jurisdictional grounds. The petitioner argued that the CFI had no appellate jurisdiction over the case. The CFI denied this motion, prompting the petitioner to file the instant petition for certiorari to annul the CFI’s decision.
ISSUE
Whether or not the then Court of First Instance (now Regional Trial Court) had appellate jurisdiction over a criminal case for grave slander decided by a municipal court.
RULING
The Supreme Court granted the petition, ruling that the CFI lacked appellate jurisdiction. The legal logic hinges on the jurisdictional framework under the Judiciary Act of 1948, as amended, which was applicable at the time the case was filed and decided by the inferior court. Grave oral defamation, under Article 358 of the Revised Penal Code, is punishable by arresto mayor in its maximum period to prision correccional in its minimum period, or a fine ranging from 200 to 6,000 pesos. This penalty placed the offense within the zone of concurrent original jurisdiction between municipal courts and courts of first instance.
Under Section 45 of the Judiciary Act, when a case falls under the concurrent original jurisdiction of municipal courts and CFIs, an appeal from the municipal court’s decision does not lie with the CFI. Instead, the appeal must be made directly to the Court of Appeals. Since the municipal court of Calapan exercised its concurrent jurisdiction in this case, Fesalvo’s appeal to the CFI was procedurally erroneous. Consequently, all proceedings before the CFI, including its decision of acquittal, were null and void for lack of jurisdiction. The Supreme Court set aside the CFI’s decision and deemed the appeal as one properly taken to the Court of Appeals, ordering the records remanded thereto for review on the merits.