Facts:

The case involves Alfredo Montelibano, Pastor Mallorca, Gonzalgo de la Torre, and Jose Articulo as petitioners and appellants against the Honorable Felix S. Ferrer, Judge of the Municipal Court of Bacolod, and Jose F. Benares as respondents and appellees. The events leading to this case began on June 13, 1953, when Jose F. Benares filed a criminal complaint against the petitioners in the Municipal Court of Bacolod, which was docketed as Case No. 2864. The complaint charged the petitioners with malicious mischief, alleging that on June 5, 7, and 8 of the same year, they conspired to willfully damage Benares' sugarcane plantation, resulting in damages exceeding P13,000. The complaint asserted that the actions were motivated by Montelibano's failed attempt to have Benares punished for contempt in a related civil case. Following the filing of the complaint, Judge Felix S. Ferrer issued a warrant for the arrest of the petitioners.

On June 22, 1953, the petitioners filed...

Facts:

Background of the Case:

• On June 13, 1953, respondent Jose F. Benares filed a criminal complaint in the Municipal Court of Bacolod City (Case No. 2864) against petitioners Alfredo Montelibano, Pastor Mallorca, Gonzalgo de la Torre, and Jose Articulo, charging them with malicious mischief.
• The complaint alleged that the petitioners, acting under the inducement of Montelibano, conspired to destroy 18 hectares of sugarcane belonging to Benares using a bulldozer, causing damages exceeding P13,000. The act was allegedly motivated by Montelibano's failed attempt to have Benares punished for contempt in a related civil case (Civil Case No. 1896).

Lease Agreement and Civil Case:

• In 1940, Capitol Subdivision Inc. (managed by Montelibano) leased Lot No. 1205-1-1 to Benares for five crop years, with an option for another five years.
• In 1951, the Subdivision filed an unlawful detainer case (Civil Case No. 1896) against Benares, resulting in a court order for his ejectment. Benares appealed, and the Court of First Instance issued a writ of preliminary mandatory injunction, requiring Benares to vacate the land.
• Benares continued planting sugarcane on the land, prompting the Subdivision to file a contempt petition, which was denied. However, the court ordered Benares to comply with the injunction.
• On June 5, 1953, the provincial sheriff delivered the land to the Subdivision. Acting on Montelibano's instructions, the petitioners cleared the land of sugarcane, leading to the criminal complaint.

Motion to Quash:

• Petitioners filed a motion to quash the criminal complaint and arrest warrant, arguing:
  1. Only the City Attorney of Bacolod, who opposed the case, could initiate criminal proceedings under the Bacolod City Charter.
  2. The case involved a prejudicial question related to the civil case.
• The Municipal Court denied the motion, prompting the petitioners to file a petition for certiorari and mandamus in the Court of First Instance, seeking to annul the proceedings and dismiss the case.

Issue:

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Ruling:

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Ratio:

1. Exclusive Authority of the City Attorney:

   • Section 22 of Commonwealth Act No. 326 (Bacolod City Charter) grants the City Attorney exclusive authority to investigate and prosecute criminal cases in Bacolod City. This provision is similar to the Charter of Manila, which has been consistently interpreted to require the City Fiscal's exclusive intervention in criminal proceedings.
   • The Court emphasized that the Bacolod City Charter's language mirrors that of the Manila Charter, and the framers intended to adopt the same interpretation. Therefore, the City Attorney of Bacolod has the sole authority to initiate criminal cases.

2. Precedents and Statutory Construction:

   • The Court cited precedents such as Espiritu v. Dela Rosa and Hashim v. Boncan, which upheld the exclusive authority of city fiscals in initiating criminal cases. These cases established that criminal complaints must be filed with the city fiscal, who then conducts the necessary investigation and files the corresponding information in court.
   • The Court applied the principle of statutory construction that reenacted statutes should be interpreted consistently with their prior judicial construction. Since the Bacolod City Charter adopted language similar to the Manila Charter, it must be interpreted in the same manner.

3. Dismissal of the Complaint:

   • Since the complaint was filed directly by Benares without the City Attorney's intervention, the Municipal Court lacked jurisdiction to entertain it. The Court held that the proper procedure was not followed, rendering the complaint invalid.

Conclusion:

The Supreme Court ruled that the Bacolod City Charter grants the City Attorney exclusive authority to initiate criminal cases. The complaint filed directly by Benares without the City Attorney's intervention was invalid, and the Municipal Court had no jurisdiction to entertain it. The decision of the Court of First Instance was reversed, and the criminal complaint was ordered dismissed.