G.R. No. L-34298 - Alger Electric, Inc. vs. Court of Appeals

On June 26, 1979, Paterno Santiago, the private respondent, was charged in the Court of First Instance (CFI) of Zamboanga del Norte, Branch III, with the crime of simple seduction.
The information charged that Santiago, by deceit and promising marriage, engaged in sexual intercourse with Araceli Medel, a 17-year-old unmarried woman, which resulted in her pregnancy.
The charge was based on a complaint originally filed by the offended party, Araceli C. Medel.

Santiago pleaded not guilty upon arraignment on September 3, 1979.
On October 22, 1979, Santiago moved to quash the information on the ground of “failure to allege lewd design,” filing a formal motion to quash and/or dismiss on October 24, 1979.
Judge Dimalanes Buissan of the CFI denied the motion but remanded the case to the City Court of Dapitan on the ground of lack of jurisdiction, citing that the penalty for simple seduction is limited to arresto mayor.

The People of the Philippines, as petitioner, filed a Motion for Reconsideration on November 26, 1979, challenging jurisdictional issues.
Judge Buissan denied the motion for reconsideration.
City Judge Wilfredo C. Martinez assumed jurisdiction of the case on April 25, 1980, scheduling the trial on its merits for May 28, 1980.
The People of the Philippines petitioned the Supreme Court for certiorari, prohibition, and mandamus, alleging grave abuse of discretion by both Judge Buissan and Judge Martinez.

The petitioner contended that the orders of Judge Buissan and Judge Martinez were illegal and void, as they improperly shifted jurisdiction from the Court of First Instance to a city court.
The main issue addressed was whether the crime of simple seduction—which is typically penalized by not more than arresto mayor and a short imprisonment term—should fall under the exclusive jurisdiction of a municipal or city court.

The case highlighted that, while simple seduction imposes a criminal penalty of arresto mayor (imprisonment of one day to six months), a conviction also necessitates accessory civil liabilities.
Such accessory liabilities include the acknowledgment of any offspring resulting from the crime and the obligation to provide support, matters which fall within the exclusive jurisdiction of the Court of First Instance.
Precedents such as U.S. vs. Bernardo and Luansing vs. People were drawn upon, reaffirming that the inherent accessory civil liabilities attached to seduction cases require that they be tried by the Court of First Instance.

Whether a criminal case charging simple seduction, penalized by imprisonment of not more than six months, falls within the exclusive jurisdiction of a municipal or city court or should be tried in the Court of First Instance.
The issue revolves around the legal interpretation of jurisdiction where the crime carries accessory civil liabilities (acknowledgment and support of the offspring) that transcend the pure penal aspect.

Whether the orders of Judge Buissan and Judge Martinez, which remanded the case to the City Court of Dapitan, are void due to an abuse of discretion in misinterpreting the proper jurisdiction.
Whether the governing statutes (Section 44(f) and Section 87(b) of Republic Act No. 296) were properly applied in assigning jurisdiction.