G.R. No. L-65773-74 - Commissioner of Internal Revenue vs. British Overseas Airways Corp.

Generoso Castrodes and Lamberto Castrodes, the petitioners, were involved in a criminal case stemming from an incident that occurred on July 10, 1975, in the barrio of Sta. Cruz, Anda, Bohol.
The accused were charged for usurpation of real property, with Lamberto additionally facing charges for grave threats.
The petition for certiorari was filed on September 9, 1977 to annul the judgment of the municipal court of Anda, Bohol dated April 28, 1976 on grounds of lack of jurisdiction.

The complaint, filed by the Chief of Police Crescencio Tongco, alleged that on July 10, 1975, Generoso and Lamberto Castrodes unlawfully entered a parcel of land that belonged to the Ampong family.
The complaint detailed that:

Generoso and Lamberto entered the land and planted coconut trees without the consent or permission of the landowners, the Ampongs.
When confronted by Julian Ampong, Generoso claimed the land belonged to the Castrodes family, while Lamberto made a threatening remark indicating that interference would result in physical harm (“the blood of the Ampongs will drain here”).

The offended parties included Julian, Benedicto, Venancio, and Josepatro Ampong, who were descendants of Damiana Simacio, and had acquired a portion of the disputed land through partition after her death.

The court ascertained familial relationships, finding that Generoso was the elder half-brother (uterine) of the offended parties.
It was established that Damiana Simacio, the mother of Generoso, originally acquired the parcel of land, which later became subject to dispute after partitioning among family members.
The court noted that:

Generoso only committed the offense of usurpation of real property.
Lamberto not only committed usurpation but allegedly also committed the additional offense of grave threats owing to his verbal intimidation.

Generoso Castrodes was convicted solely for usurpation of real property and was sentenced to pay a fine of P350, with subsidiary imprisonment in case of insolvency; he eventually served the subsidiary imprisonment.
Lamberto Castrodes was convicted of the complex crime of usurpation of real property with grave threats.

His penalty was an indeterminate sentence ranging from four months and one day of arresto mayor, as minimum, to five years of prision correccional as maximum.
Lamberto served his sentence in New Bilibid Prison but was later paroled on August 10, 1977.

The petitioners raised issues concerning the municipal court’s jurisdiction, particularly with respect to the imposition of the penalty on Lamberto Castrodes.

Whether the municipal court had jurisdiction to impose the penalty meted to Lamberto Castrodes, given the nature of the offense charged.
Whether the municipal court’s imposition of an indeterminate penalty for a crime including grave threats was authorized by law.

Whether the complaint properly charged Lamberto Castrodes with the complex crime of usurpation of real property with grave threats.
Whether the threat uttered by Lamberto constituted a distinct or a qualifying element that inherently merged into the single offense of usurpation of real property.