G.R. No. 217368 - Ruby Shelter Builders and Realty Development Corporation vs. Romeo Y. Tan, Roberto L. Obiedo and Atty. Tomas A. Reyes

On March 1, 1971, a vehicular collision occurred in Tubigon, Bohol involving a jeep and a Volkswagen Combi.
The jeep, owned by the Tagbilaran Branch of the Philippine National Bank (PNB), was regularly driven by Reno Arcaya, who allegedly allowed Emmanuel Ceballos—a fellow PNB employee—to drive it.
The collision resulted in bodily injuries to passengers in the Combi and inflicted damages upon both vehicles.
The injured parties included Doctor Remedios N. Relampagos, Paz F. Nazareno (both suffering less serious physical injuries), and Mary Carlyn Relampagos (a minor who sustained lesiones leves), as well as Doctor Domiciano Nazareno, the owner of the damaged Combi.

On April 27, 1971, the chief of police of Tubigon charged Arcaya and Ceballos before the municipal court with multiple offenses through Criminal Case No. 1397, alleging “double less serious physical injuries, slight physical injuries and damage to property through reckless imprudence.”
In response to the initial complaint, Arcaya and Ceballos, through their counsel Manuel Estimo, moved to quash the complaint on two main grounds:

The improper joinder of three offenses in a single indictment, with the contention that such offenses were “incomplexible.”
The argument that the crime of lesiones leves had already prescribed.

An amended complaint (retaining Criminal Case No. 1397) for less serious physical injuries and damage to property through reckless imprudence.
A separate complaint (docketed as Criminal Case No. 1397-A) for the light felony of slight physical injuries (lesiones leves) through reckless imprudence, effectively segregating this offense from the more serious charges.

The municipal court denied the motion to quash the complaints despite the amended pleadings.
Arcaya and Ceballos then sought relief by filing actions for certiorari and prohibition in the Court of First Instance of Bohol, which dismissed their petition on April 12, 1973.
Later, the petitioners filed actions for certiorari, prohibition, and mandamus before the Supreme Court on September 10, 1973, challenging:

The assertion that the filing of Criminal Case No. 1397 “conferred jurisdiction” on the municipal court for the joined offenses.
The determination that the municipal court had jurisdiction over the allegedly prescribed light felony in Criminal Case No. 1397-A.

After Criminal Case No. 1397 was elevated to the Court of First Instance, a related information (Criminal Case No. 806) for the complex crime of less serious physical injuries and damage to property was filed against Arcaya and Ceballos.
Subsequent petitions for certiorari, mandamus, and prohibition concerning Criminal Case No. 806 and related civil actions (Civil Case No. 2250 involving a claim for damages) were also dismissed at various levels as no jurisdictional errors were found.

Whether the filing of the complaint in Criminal Case No. 1397 properly conferred jurisdiction on the municipal court over the joined offenses.
The petitioners’ contention that a complaint cannot by itself confer jurisdiction, as jurisdiction is inherently bestowed by law.

Whether the offense of slight physical injuries (lesiones leves) charged in Criminal Case No. 1397-A had prescribed, given that it was allegedly charged beyond the prescribed period for light felonies.
Whether the separation of the light felony from the more serious offenses, through the amendment of the complaint, impacted the computation of the prescriptive period and the municipal court’s jurisdiction.

Whether the lower courts committed any jurisdictional error or grave abuse of discretion that would render their orders subject to review by the writ of certiorari.
Whether errors stemming from the exercise of judicial judgment, as opposed to jurisdictional defects, can be corrected through this extraordinary remedy.