Case Digest (G.R. No. L-31949)
Facts:
The People of the Philippines v. Ildefonso Brecinio, G.R. No. L-31949, October 26, 1983, Supreme Court Second Division, Abad Santos, J., writing for the Court.
The appellant is Ildefonso Brecinio (accused-appellant); the appellee is The People of the Philippines (plaintiff-appellee).
Brecinio was charged in the Justice of the Peace Court of Pili, Camarines Sur, with stealing a male carabao valued at P150.00. Jurisdiction of that court had been treated as concurrent with the Court of First Instance (CFI) of Camarines Sur in an earlier decision, Brecinio v. Papica, 120 Phil. 1141 (1964), which the parties and lower courts had previously relied upon.
The Justice of the Peace (municipal) court tried and convicted Brecinio, but its proceedings were not recorded. Despite that conviction, an appeal was taken to the Court of First Instance of Camarines Sur. The CFI observed that, strictly speaking, appeals from a justice of the peace acting with concurrent jurisdiction should go to the Court of Appeals (see Esperat v. Avila, L-25922, June 30, 1967), but noted that neither party in the present case questioned the CFI’s jurisdiction and therefore proceeded to try the case “in the exercise of such [original concurrent] jurisdiction.”
After receiving testimonial and documentary evidence, the CFI rendered judgment on July 24, 1968, finding Brecinio guilty and imposing imprisonment and costs; the carabao having been recovered, no indemnity was ordered. On the same day Brecinio filed a notice of appeal. He assigned two errors: (1) that the CFI erred in taking cognizance in its original concurrent jurisdiction after the municipal court had already convicted him, and ...(Pro-only)
Issues:
- Did the Court of First Instance err in taking cognizance of the case in the exercise of its original concurrent jurisdiction despite the prior conviction by the municipal (Justice of the Peace) court?
- Did the prosecution and judgment by the Court of First Instance subject Brecinio to double jeopardy, given the previous ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)