Case Digest (G.R. No. L-14207)
Facts:
The People of the Philippines v. Hon. Dionisio Vendiola, G.R. No. L-14207, May 30, 1962, the Supreme Court En Banc, Bautista Angelo, J., writing for the Court. The criminal information filed on February 3, 1958 charged Pedro Capuno with the complex crime of serious physical injuries and damage to property through reckless imprudence before the Justice of the Peace Court of Sariaya, Quezon. The justice of the peace conducted the preliminary investigation, issued an arrest warrant and set the case for trial on the merits.The Provincial Fiscal refused to enter the trial, contending the case was beyond the jurisdiction of the Justice of the Peace under the Judiciary Act of 1948, as amended, and that the justice of the peace’s role had been limited to the preliminary investigation. After his objection was overruled, the fiscal filed a petition for prohibition with preliminary injunction in the Court of First Instance of Quezon, arguing lack of jurisdiction by the justice of the peace. The justice of the peace filed a reply memorandum.
The Court of First Instance denied the fiscal’s petition, reasoning that the amended complaint failed to allege a specific amount of damage to the property (a horse) and that the only damage shown was a fracture of one leg of a horse valued at P320.00; the court evaluated the value of a single leg as a...(Subscriber-Only)
Issues:
- Did the Justice of the Peace Court of Sariaya have original jurisdiction to try the complex crime charged?
- Does Article 48 of the Revised Penal Code (imposition of the penalty for the most serious crime in a complex offense) permit an inferior court to try a complex crime when one component (damage to property) carries a fine beyond that cou...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)