Title
Natividad vs. Robles
Case
G.R. No. L-3612
Decision Date
Dec 29, 1950
Petitioners challenged jurisdiction of Justice of Peace Court over qualified trespass to dwelling; Supreme Court ruled concurrent jurisdiction with Court of First Instance.

Case Digest (G.R. No. L-3612)

Facts:

This is Avelino Natividad, Pedro Gabriel, and Miguel Evangelista v. Ricardo C. Robles, G.R. No. L-3612, December 29, 1950, the Supreme Court En Banc, Moran, C.J., writing for the Court.

Petitioners Avelino Natividad, Pedro Gabriel, and Miguel Evangelista were charged on August 18, 1949, in the Justice of the Peace Court of Malabon, Rizal, with qualified trespass to dwelling. After a preliminary investigation, the Justice of the Peace court purportedly elevated the case to the Court of First Instance (CFI) of Rizal for trial on the merits.

The Assistant Provincial Fiscal of Rizal, however, did not file an information in the CFI and instead requested that the CFI return the case to the Justice of the Peace court for trial on the merits. The Justice of the Peace court set the case for trial. Petitioners then filed the instant petition for prohibition in the Supreme Court to prevent the Justice of the Peace court from trying them, contending that original jurisdiction to try the offense lay with the Court of First Instance.

The lower forums’ formal acts were limited: the Justice of the Peace conducted a preliminary investigation and attempted to elevate the case; the CFI returned the case on the prosecutor’s request rather than trying it; no further trial proceedings by the...(Subscriber-Only)

Issues:

  • Did the Justice of the Peace Court of Malabon have original jurisdiction to try the offense of qualified trespass to dwelling charged against the petitioners?
  • If both courts have jurisdiction over the offense, are the jurisdictional powers of the Justice of the Peace court and the Court of First Instance concurrent when the penalty provided by law exceeds six months’ imprisonm...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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