Facts:

• Lt. Col. Rodrigo S. De Guzman and the People of the Philippines filed a petition challenging the jurisdiction of Municipal Circuit Judge Marcelino M. Escalona.
• The case involved illegal possession of explosives for illegal fishing.
• The accused, Florentino Rodrigo and Mariano Dayday, were charged with illegal possession of explosives known as "dinamita" for use in illegal fishing.
• The complaint was filed after CIC Carlos Dosdos and Sgt. Jose Andales conducted a seaborne patrol and arrested the accused, confiscating three bottles of dynamite and two fishnets from them.
• Instead of conducting a preliminary investigation, the respondent judge treated the complaint as one for Violation of Act 3023 and rendered a decision finding the accused guilty of illegal possession of explosives.
• Both accused served their sentence.

Issue:

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Ruling:

• The Court found that the respondent Judge exceeded his jurisdiction when he rendered the decision.
• The offense charged, illegal possession of explosives intended for illegal fishing, falls within the exclusive original jurisdiction of the Courts of First Instance.
• The Municipal Judge's jurisdiction in a preliminary investigation is limited to determining whether there is probable cause to hold the accused for trial or to dismiss the case.
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Ratio:

• The Court based its decision on the jurisdictional limits of the Municipal Circuit Court and the purpose of a preliminary investigation.
• The Municipal Judge's jurisdiction is limited to conducting a preliminary investigation and determining whether there is probable cause to hold the accused for trial or to dismiss the case...continue reading