Case Digest (G.R. No. 254001) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Hon. Judge Mericia B. Palma and Romulo Intia y Morada, G.R. No. L-44113, decided on March 31, 1977 under the 1973 Constitution, the People of the Philippines charged 17-year-old Romulo Intia y Morada with vagrancy (Art. 202(2), Revised Penal Code) on February 10, 1976. The case was filed before the City Court of Naga, presided over by Judge Mericia B. Palma. On March 6, 1976, Judge Palma dismissed the complaint for lack of jurisdiction, reasoning that Presidential Decree No. 603 (the Child and Youth Welfare Code) defined “youthful offenders” as those over nine but under 21 years of age and thus transferred jurisdiction over 16- to under-21-year-olds from regular courts to the Juvenile and Domestic Relations Court of Camarines Sur. The People, joined by the Camarines Sur Juvenile Court, filed a petition with the Supreme Court to resolve this conflict of jurisdiction and to reinstate the vagrancy case.Issues:
- Did Presidential Decree No. 603’s def
Case Digest (G.R. No. 254001) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Petitioner: People of the Philippines.
- Respondents: Hon. Judge Mericia B. Palma (City Court of Naga) and accused Romulo Intia y Morada.
- Jurisdictional Conflict
- City Court of Naga vs. Juvenile and Domestic Relations Court (JDRC) for Camarines Sur over criminal cases where the accused is 16 but under 21 years old.
- R.A. 6591 (effective September 30, 1972) expressly grants JDRC jurisdiction only over offenders under 16 at the time of filing.
- P.D. 603 (Child and Youth Welfare Code, effective June 11, 1975) defines a “youthful offender” as one over 9 but under 21 at the time of the offense.
- Case at Bar
- On February 10, 1976, Romulo Intia y Morada, age 17, was charged with vagrancy (RPC Art. 202, par. 2) in the City Court of Naga.
- On March 6, 1976, Judge Palma dismissed the case for lack of jurisdiction and ordered refiling in the Juvenile Court.
- The People filed a petition for certiorari and prohibition before the Supreme Court to resolve the jurisdictional issue.
Issues:
- Whether the definition of “youthful offender” in P.D. 603 (over 9 but under 21) transferred jurisdiction over 16–under 21 offenders from regular courts to the Juvenile Courts.
- Whether a general law (P.D. 603) can impliedly repeal or expand the special and limited jurisdiction conferred by R.A. 6591 on the JDRC of Camarines Sur.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)