Case Digest (G.R. No. L-23079) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 7, 1976, the City Court of Roxas City docketed Criminal Case No. 7362 upon a criminal information filed by the City Fiscal, charging private respondent Libertad Lagon with estafa under paragraph 2(d), Article 315 of the Revised Penal Code. The information alleged that on April 5, 1975, Lagon issued a P4,232.80 check to cover payment for merchandise, knowing at the time she lacked sufficient funds, and that the check subsequently bounced. The case proceeded to trial, but on December 2, 1976, the presiding judge, Hon. Isidro O. Barrios, dismissed the information on the ground that the penalty then imposed by law—after amendment by Presidential Decree No. 818 effective October 22, 1975—exceeded the City Court’s jurisdictional limit. The judge ruled that subject‐matter jurisdiction is measured by the penalty prescribed at the time of filing, not at the time of the crime. The People of the Philippines filed a Petition for Review before the Supreme Court, contending that the C Case Digest (G.R. No. L-23079) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Filing and Nature of Charge
- On July 7, 1976, a criminal information was filed in the City Court of Roxas City as Criminal Case No. 7362.
- Private respondent Libertad Lagon was charged with estafa under paragraph 2(d) of Article 315 of the Revised Penal Code for issuing a bounced check in the amount of ₱4,232.80 knowing she had insufficient funds.
- Trial Proceedings and Dismissal
- The prosecution commenced presenting evidence at the trial.
- On December 2, 1976, the City Court dismissed the information on the ground that the penalty then prescribed by law was beyond its authority to impose, applying the law in force at the time of filing rather than at the time of commission.
- Legislative and Jurisdictional Background
- At the time of the alleged commission (April 5, 1975), the penalty under paragraph 2(d) of Article 315 was arresto mayor (maximum) to prision correccional (minimum), within City Court jurisdiction.
- By October 22, 1975, Presidential Decree No. 818 increased the penalty to prision mayor (medium period), exceeding the City Court’s statutory limit under Section 87, Judiciary Act of 1948.
- Petition for Review
- The People filed a Petition for Review before the Supreme Court, arguing the City Court had jurisdiction and erred in dismissing the information.
- The Office of the Solicitor General, upon referral, agreed with the City Fiscal’s position that the City Court possessed jurisdiction.
Issues:
- Subject-Matter Jurisdiction
- Is a municipal or city court’s jurisdiction in criminal cases determined by the law in effect at the time of the commission of the offense or at the time of the institution of the action?
- Retroactivity of Penal Laws
- Would applying the increased penalty under P.D. No. 818 for jurisdictional classification constitute an impermissible retroactive application of penal legislation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)