Facts:

The case at hand, Crispiniano V. Laput and Catalino Salas vs. Jose Bernabe, Judge, First Branch, Municipal Court, City of Manila, was decided by the Supreme Court of the Philippines on February 12, 1931. The controversy began when Catalino Salas was charged with damage to property through reckless imprudence at the municipal court of Manila. Salas appointed Crispiniano V. Laput, a law student and not a licensed attorney, to represent him in this legal matter. Salas' written appointment was submitted to the court; however, the presiding judge, Jose Bernabe, refused to permit Laput to act as Salas' counsel. As a result, Laput, on behalf of Salas, filed a petition for a writ of mandamus to compel the judge to acknowledge Salas’ right to representation by an agent or friend who was not a licensed attorney. The legal context is rooted in various legislative measures, including the Judiciary Law (Act No. 136), the Manila Charter (Act No. 183), and the Code of Civil Procedure (

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Facts:

1. Parties Involved:

   • Petitioners: Crispiniano V. Laput (a law student) and Catalino Salas (accused).
   • Respondent: Judge Jose Bernabe of the First Branch, Municipal Court, City of Manila.

2. Case Background:

   • Catalino Salas was charged with the crime of damage to property through reckless imprudence in the municipal court of Manila.
   • Salas appointed Crispiniano V. Laput, a law student and not a licensed attorney, to represent him in the case.
   • The respondent judge refused to allow Laput to act as Salas's counsel, prompting the petitioners to file a petition for a writ of mandamus.

3. Legal Context:

   • The case revolves around the interpretation of Section 34 of the Code of Civil Procedure, which allows a party to conduct litigation in a justice of the peace court with the aid of an agent or friend, even if the agent is not a licensed attorney.
   • The municipal court of Manila was created to replace the justice of the peace courts, but the applicability of Section 34 to the municipal court was disputed.

Issue:

1. Whether the municipal court of Manila is considered a "court of a justice of the peace" under Section 34 of the Code of Civil Procedure.
2. Whether a non-lawyer agent or friend can represent an accused in the municipal court of Manila.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court held that the municipal court of Manila is a "court of a justice of the peace" under Section 34 of the Code of Civil Procedure, allowing non-lawyer agents or friends to represent litigants. The writ of mandamus was granted, and Laput was permitted to aid Salas in his defense.