G.R. No. L-38579 - Dioquino vs. Cruz

Two related cases were elevated to the Supreme Court involving the issue of proper court jurisdiction over criminal prosecutions for simple seduction.
In one case (G.R. No. L-38579), petitioner Juliet T. Dioquino, assisted by her mother, Natividad Tullao, sought relief from the Municipal Court of Parañaque’s proceedings in Criminal Case No. L-35936.
In the other case (G.R. No. L-39951), the People of the Philippines, represented by the respondent Judge Victorino A. Savellano of the Court of First Instance of Manila, had dismissed Criminal Case No. 17765 for seduction and ordered the Fiscal to file the case in the “proper” court.

Article 338 of the Revised Penal Code defines simple seduction and imposes a penalty of arresto mayor.

Arresto mayor is punishable by imprisonment ranging from one month and one day to six months.

Section 87(c) of the Judiciary Act (as amended) grants municipal judges and judges of city courts original jurisdiction over offenses with imprisonment not exceeding three years, among other penalties.

In G.R. No. L-38579, Judge Pedro A. Revilla of the Court of First Instance of Rizal ruled that simple seduction falls under the original jurisdiction of the municipal court, leading him to dismiss the petition for certiorari, prohibition, and mandamus.
In G.R. No. L-39951, Judge Savellano of Manila dismissed the seduction case on the ground that the penalty prescribed (arresto mayor) fell under the exclusive original jurisdiction of the City Court and that the establishment of the Juvenile and Domestic Relations Court confirmed such jurisdiction for matters involving acknowledgment of offspring.
The cases raised issues stemming from the accessory civil liabilities under Article 345 of the Revised Penal Code, which impose additional obligations on the offender (indemnification, acknowledgment, and support for offspring).

The Luansing v. Court of Appeals case was cited, which explained that when a crime such as simple seduction carries inherent accessory civil liabilities (acknowledgment and support of the offspring), the jurisdiction of the Court of First Instance is implicated.
Additional cases such as U.S. v. Bernardo, People v. Cuello, People v. Co Hiok, and others were considered to emphasize that jurisdiction is determined by the penalty prescribed in the law and the nature of the liability attached to the offense.
The decision underscored that the subsequent absence of an offspring or changes in circumstances should not affect the court’s jurisdiction once it is properly invoked.

In Criminal Case No. L-35936, the proceedings in the municipal court were at an advanced stage, with the prosecution nearly completing the presentation of evidence when a motion for discontinuance was filed.
The Court of First Instance of Rizal had ruled on the matter over sixteen months after the alleged commission of the crime, by which time the possibility of a resulting offspring had become factually irrelevant.

Whether the crime of simple seduction, as defined under Article 338 of the Revised Penal Code, falls within the original jurisdiction of the Municipal or City Courts or that of the Court of First Instance.
Whether the additional civil liabilities under Article 345 (acknowledgment of offspring and support) necessitate the action being tried in the Court of First Instance, regardless of the penalty seat.

Whether subsequent factual developments (such as the absence of an offspring) can alter or diminish the jurisdiction originally attached to the court based on the complaint.
The contention raised that a separate suit for acknowledgment and support should be directed to the Juvenile and Domestic Relations Court, and whether such bifurcation is warranted.

How lower courts should reconcile conflicting decisions, particularly in light of the established precedent in Luansing v. Court of Appeals and the principles embodied in other cited cases.
The extent to which the doctrine of stare decisis mandates adherence to settled jurisprudence in criminal jurisdiction matters.