G.R. No. 45815 - People vs. Lagon

PEOPLE OF THE PHILIPPINES as Petitioner and LIBERTAD LAGON as private respondent were the principal parties; HON. JUDGE ISIDRO O. BARRIOS was sued in his official capacity as Presiding Judge of the City Court of Roxas City.
A criminal information was filed with the City Court of Roxas City on 7 July 1976 and docketed as Criminal Case No. 7362 charging estafa under paragraph 2(d) of Article 315 of the Revised Penal Code.
The information alleged that respondent Lagon issued a check in the amount of P4,232.80 as payment for goods or merchandise, knowing she did not have sufficient funds to cover the check, and that the check subsequently bounced.
The alleged commission of the offense occurred on 5 April 1975.
The case proceeded to trial and the prosecution commenced presentation of evidence before the trial court acted.

In an Order dated 2 December 1976, the City Court dismissed the information on the ground that the penalty prescribed by law for the offense charged was beyond the City Court’s authority to impose.
The City Court held that subject-matter jurisdiction is determined by the law in force at the time of the institution of the action and not by the law in force at the time of the commission of the crime.
The City Court reasoned that at the time of commission (April 1975) the penalty under paragraph 2(d), Article 315 RPC fell within the City Court’s competence, but by the time of filing (7 July 1976) Presidential Decree No. 818 (effective 22 October 1975) had increased the penalty beyond the City Court’s authority.
The City Court dismissed the information without prejudice to its refiling in the proper court.

Whether the City Court of Roxas City had subject-matter jurisdiction over Criminal Case No. 7362 given that the information was filed on 7 July 1976 after Presidential Decree No. 818 increased the penalty for the offense.
Whether the rule that subject-matter jurisdiction in criminal cases is measured by the law in effect at the time of commencement of the action would improperly apply P.D. No. 818 retroactively in violation of the rule against retroactivity of penal laws, specifically Article 22 of the Revised Penal Code.
Whether dismissal of t...(Subscriber-Only)