G.R. No. L-46753-54 - Solis vs. Court of Appeals

Pacianito S. Paraguya, an internal revenue examiner (BIR Agent) assigned at the Bureau of Internal Revenue District Office in Cagayan de Oro City, was charged with indirect bribery.
The charge stemmed from an incident on or about October 10, 1968, where Paraguya allegedly, without authority of law, willfully, unlawfully, and feloniously demanded, solicited, and received a gift—a sum of Three Hundred Pesos—from Sia Bon Suan, a stockholder and manager of a local cockpit business at the Cagayan Gold City Coliseum.

An information charging Paraguya with the crime of indirect bribery was filed in Criminal Case No. 48 of the Circuit Criminal Court of the Fifteenth Judicial District, Cagayan de Oro City.
Paraguya moved to quash the information on the ground of lack of jurisdiction, arguing that the Circuit Criminal Court was not authorized to hear cases for indirect bribery.
The contention was based on Republic Act No. 5179, which created the circuit criminal courts with limited jurisdiction, applicable only to certain crimes committed by public officers or those involving penalties exceeding specific minimum thresholds.
The Circuit Judge, in an order dated January 23, 1969, denied the motion for lack of merit and scheduled the hearing for January 27, 1969.
After a subsequent denial of a motion for reconsideration on January 27, 1969, Paraguya filed the present petition for certiorari questioning the respondent judge’s jurisdictional orders.

Paraguya’s defense asserted that since indirect bribery under Article 211 of the Revised Penal Code carries penalties of arresto mayor (with imprisonment not exceeding six months), suspension, and public censure, the case should fall under the exclusive jurisdiction of the city or municipal courts rather than the circuit criminal court.
The argument underscored that the creation of circuit criminal courts by Republic Act No. 5179 is limited to cases involving crimes for which the penalty is imprisonment for more than three years (or a fine in excess of the prescribed minimum amounts), thereby excluding offenses like indirect bribery.

Republic Act No. 5179 specifically provided for the creation of Circuit Criminal Courts in the judicial districts, confining their jurisdiction to:

Crimes committed by public officers, crimes against persons, and crimes against property as defined and penalized under the Revised Penal Code.
Violations of special laws such as the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019) and provisions of the Tariff and Customs Code and the Internal Revenue Code, subject to them falling within the exclusive jurisdiction of the regular courts.

The statutory language emphasized that the circuit criminal courts’ jurisdiction is “limited merely” to the cases enumerated, and it serves the purpose of dispensing speedy justice in grave and penalizing cases.
Judicial precedents (e.g., People vs. Paderna, L-28518) were cited to illustrate that the jurisdiction of these courts depends not solely on the nature of the offense but also on the severity of the penalties provided by law.

Whether the Circuit Criminal Court had jurisdiction over the case involving indirect bribery when the charge, though committed by a public officer, does not meet the statutory penalty threshold prescribed for cases under Republic Act No. 5179.
Whether the mere fact that the offense was committed by a public officer is sufficient to confer jurisdiction on the Circuit Criminal Court, given that the prescribed penalty under Article 211 of the Revised Penal Code is limited (imprisonment not exceeding six months, suspension, and public censure).
How the statute’s limitation on the jurisdiction of the Circuit Criminal Courts—restricted to cases with penalties exceeding three years imprisonment or corresponding fine thresholds—applies to a case of indirect bribery.