Case Digest (G.R. No. L-20347)
Facts:
The case involves Ildefonso Brecinio as the petitioner and appellant against Nicolas Papica, the Justice of the Peace of Pili, Camarines Sur, and other respondents. The events leading to this case began when Brecinio was accused of stealing a carabao valued at P150.00, owned by Teodolo Barientes. The accusation was filed in the Justice of the Peace Court of Pili, Camarines Sur. Brecinio contested the jurisdiction of the Justice of the Peace Court, arguing that the case should be under the jurisdiction of the Court of First Instance because the penalty for the crime of qualified theft exceeds six months of imprisonment. The Justice of the Peace Court denied Brecinio's motion to dismiss, asserting that it had concurrent jurisdiction with the Court of First Instance. Subsequently, Brecinio elevated the matter to the Court of First Instance of Camarines Sur through a petition for certiorari, which also ruled against him, affirming that the Justice of the Peace Court had the a...
Case Digest (G.R. No. L-20347)
Facts:
Parties Involved:
- Petitioner/Appellant: Ildefonso Brecinio
- Respondents/Appellees: Nicolas Papica, Justice of the Peace, Pili, Camarines Sur, et al.
Nature of the Case:
- Ildefonso Brecinio was accused of qualified theft before the Justice of the Peace Court of Pili, Camarines Sur, for allegedly stealing a carabao worth P150.00 belonging to Teodolo Barientes.
Procedural History:
- Brecinio filed a motion to dismiss the case, arguing that the Justice of the Peace Court lacked jurisdiction because the penalty for qualified theft exceeded six months, and jurisdiction should belong to the Court of First Instance.
- The Justice of the Peace Court denied the motion, asserting concurrent jurisdiction with the Court of First Instance.
- Brecinio elevated the matter to the Court of First Instance of Camarines Sur via certiorari, which also ruled in favor of concurrent jurisdiction and dismissed the petition.
- Brecinio appealed to the Supreme Court.
Key Legal Issue:
- Whether the Justice of the Peace Court has jurisdiction to try a case of qualified theft involving property valued at less than P200.00, given that the penalty imposable exceeds six months.
Issue:
Primary Issue:
- Does the Justice of the Peace Court have jurisdiction over qualified theft cases where the value of the stolen property does not exceed P200.00, despite the penalty imposable being more than six months?
Subsidiary Issue:
- Whether the Court of Appeals' decision in People vs. Bacolongon (which suggested that jurisdiction in theft cases involving large cattle is determined by the penalty, not the value) should override the Supreme Court's established jurisprudence on concurrent jurisdiction.
Ruling:
The Supreme Court affirmed the decision of the Court of First Instance of Camarines Sur, holding that the Justice of the Peace Court has concurrent jurisdiction with the Court of First Instance over qualified theft cases where the value of the stolen property does not exceed P200.00. The Court ruled that the Justice of the Peace Court properly took cognizance of the case, and the appeal was dismissed.
Ratio:
Concurrent Jurisdiction:
- Under Section 87(c) (now Section 87(b)) of the Judiciary Act, as amended, Justice of the Peace Courts and Courts of First Instance have concurrent jurisdiction over criminal cases involving larceny, embezzlement, and estafa where the amount or value of the property does not exceed P200.00.
- This includes qualified theft cases, regardless of the penalty imposable.
Established Jurisprudence:
- The Supreme Court reiterated its rulings in People vs. Palmon (1950) and Natividad vs. Robles (1950), which affirmed the concurrent jurisdiction of Justice of the Peace Courts and Courts of First Instance over such cases.
- The Court emphasized that the value of the stolen property (not exceeding P200.00) determines jurisdiction, not the penalty imposable.
Rejection of Court of Appeals' Obiter Dictum:
- The Court dismissed Brecinio's reliance on the Court of Appeals' decision in People vs. Bacolongon, which suggested that jurisdiction in theft cases involving large cattle is determined by the penalty.
- The Supreme Court clarified that its decisions prevail over those of the Court of Appeals, and the doctrine of concurrent jurisdiction remains controlling.
Purpose of the Appeal:
- The Court noted that the appeal appeared to be merely for delay, as Brecinio and his counsel were aware of the Supreme Court's established jurisprudence on the matter.
Conclusion:
The Supreme Court upheld the concurrent jurisdiction of Justice of the Peace Courts and Courts of First Instance over qualified theft cases involving property valued at less than P200.00. The appeal was dismissed, and Brecinio was ordered to pay treble costs.