Title
Chan Lin vs. Del Rosario
Case
G.R. No. 12623
Decision Date
Mar 27, 1917
The Supreme Court upholds the Manila municipal court's jurisdiction over a gambling case, rejecting claims of lack of jurisdiction based on the applicable law.
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Case Digest (G.R. No. 12623)

Facts:

  • Petitioners Chan Lin and Lee Lion were convicted by the municipal court of Manila for participating in a gambling game.
  • They were arrested and charged under the Gambling Law, specifically Act No. 1757.
  • The petitioners appealed to the Court of First Instance of Manila, filing a demurrer to challenge the municipal court's jurisdiction.
  • They argued that the municipal court lacked jurisdiction because the Gambling Law allowed for penalties exceeding six months of imprisonment and a fine of P200.
  • The Court of First Instance overruled the demurrer, conducted a trial, and convicted the petitioners, imposing a fine of P100 each.
  • The petitioners appealed to the Supreme Court, asserting that the municipal court had no jurisdiction, which rendered all proceedings ineffective.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the municipal court of Manila had jurisdiction over the gambling offense charged against the petitioners.
  • Consequently, the Court of First Instance had the authority to hear the appe...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the interpretation of jurisdictional statutes in effect at the time.
  • The petitioners claimed that the municipal court's jurisdiction was limited by the Act of Congress of July 1, 1902.
  • The Court clarified that the municipal court was operating under the jurisdiction granted by Act No. 267, which provided it with concurrent jurisdiction with the Court of First Instance over violations o...continue reading

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