Title
People vs. Palma
Case
G.R. No. L-44113
Decision Date
Mar 31, 1977
A 17-year-old charged with vagrancy; jurisdictional dispute arose over whether Juvenile Court or regular courts had authority under R.A. 6591 and P.D. 603. Supreme Court ruled regular courts retain jurisdiction for accused aged 16-21.

Case Digest (G.R. No. 254001)
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)

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