G.R. No. L-47448 - People vs. Ocaya

The provincial fiscal of Bukidnon, after conducting a preliminary investigation, filed an information on October 13, 1977, in the court of respondent judge (Hon. Emeterio C. Ocaya).
The information charged Esterlina Marapao, Leticia Marapao, and Diosdado Marapao with serious physical injuries under Article 263, paragraph 3, of the Revised Penal Code.
The charges stemmed from an incident on July 23, 1977, in Don Carlos, Bukidnon, where the accused allegedly attacked Mrs. Lolita Ares, a mother twelve days after childbirth.
The information detailed that the accused wrestled Lolita Ares to the ground and hit her face with a fist-size stone, inflicting a lacerated wound approximately 2.5 cm x 0.5 cm on her maxillary arch, causing contusion, swelling, and a significant facial deformity.
The injuries purportedly caused a relapse due to her weakened condition, incapacitating her from customary labor for over thirty days.

Without arraignment or trial, and relying primarily on a medical certificate attached to the case records which stated the injuries required 7 to 10 days of medical attention, respondent judge dismissed the case for lack of jurisdiction on October 27, 1977.
The judge reasoned that the case was one of slight or less serious physical injuries (not serious injuries), which fell outside his court's jurisdiction.
He prioritized the medical certificate's duration of treatment over the victim’s affidavit, dismissing the victim’s testimony as “self-serving.”
The provincial fiscal moved for reconsideration, which the respondent judge denied on November 16, 1977, also expressing doubts about the alleged facial scar’s relevance and location.

The provincial fiscal petitioned the Supreme Court to nullify the orders dismissing the case.
The Solicitor General, in his comment, emphasized the adequacy of the information, evidence, and the charges for serious physical injuries and underscored the jurisdiction of respondent judge's court.

Whether the respondent judge had jurisdiction over the serious physical injuries case based on the allegations in the information.
Whether the dismissal of the information for lack of jurisdiction prior to arraignment and trial was proper.
Whether respondent judge committed grave abuse of discretion in dismissing the case on the basis of the medical certificate and discrediting the victim’s testimony.
Whether the case should be transferred to another branch due to possible prejudgment by the respondent judge.