GR L 6641; (July, 1955) (Digest)
G.R. No. L-6641; July 28, 1955
FRANCISCO QUIZON, petitioner, vs. THE HON. JUSTICE OF THE PEACE OF BACOLOR, PAMPANGA, ET AL., respondents.
FACTS
On December 19, 1952, the Chief of Police of Bacolor, Pampanga, filed a criminal complaint against petitioner Francisco Quizon with the Justice of the Peace Court, charging him with damage to property through reckless imprudence, with the value of damage amounting to P125.00. Quizon filed a motion to quash, arguing that under Article 365 of the Revised Penal Code, the imposable penalty would be a fine equal to three times the value of the damage (P125.00 to P375.00), which exceeds the fine that a justice of the peace court may impose. The Justice of the Peace forwarded the case to the Court of First Instance of Pampanga, but the latter returned it, holding that the justice of the peace court had jurisdiction. Quizon appealed this ruling to the Supreme Court on a question of law.
ISSUE
Whether the justice of the peace court has concurrent jurisdiction with the Court of First Instance to try a case of damage to property through reckless negligence (imprudence) where the amount of damage is P125.00, given that Section 87(c)(6) of the Judiciary Act of 1948 grants justices of the peace original jurisdiction over cases arising under laws relating to “malicious mischief.”
RULING
The Supreme Court ruled that the justice of the peace court does not have jurisdiction. The offense of damage to property through reckless negligence or imprudence is not included within the term “malicious mischief” as used in Section 87(c)(6) of the Judiciary Act. Malicious mischief, as defined in Article 327 of the Revised Penal Code, requires a specific deliberate intent to cause injury (“animo especifico de dañar”). This specific malice is inherently incompatible with negligence (culpa). Therefore, malicious mischief cannot be committed through imprudence. The jurisdiction granted to justices of the peace over “malicious mischief” refers exclusively to the willful crimes described in Articles 327 to 331 of the Revised Penal Code and does not extend to offenses of criminal negligence resulting in property damage. Since the imposable fine (P125.00 to P375.00) exceeds the P200.00 limit of the justice of the peace court’s general jurisdiction, and the case does not fall under the specific exception for “malicious mischief,” jurisdiction lies exclusively with the Court of First Instance. The writ of certiorari was granted, and the order remanding the case to the Justice of the Peace Court was reversed and set aside.