G.R. No. 183053 - Suntay III vs. Cojuangco-Suntay

On May 9, 1975, the City Fiscal of Manila charged private respondent Josefa Pesimo before the Court of First Instance of Manila.
The charge was for the violation of Section 16 of Act 3753, otherwise known as the “Civil Register Law,” which penalizes the making of false statements in the Certificate of Live Birth.

The offense arose from statements made on or about January 20, 1969, in the Certificate of Live Birth for Carlos Pesimo Cucueco, Jr.
The alleged false statements purported that:

The child was the legitimate offspring of one Carlos Layug Cucueco.
The respondent had been married to Carlos Layug Cucueco on April 3, 1962, at San Jose, Camarines Sur.

It was contended that these statements were knowingly false, as the respondent was never married to the said Carlos Layug Cucueco and the child was not legitimate as claimed.

The offense was punishable by either imprisonment for not less than one month and not more than six months, or by a fine of not less than P200.00 and not more than P500.00, or by both penalties in the discretion of the court.
The dual penalty provision (imprisonment and fine) suggested that either imposition would determine the court’s competence under the law.

On May 26, 1975, the respondent Court of First Instance dismissed the case ex mero motu.
The dismissal was based on the contention that the prescribed penalty of six (6) months imprisonment fell below the threshold of its original jurisdiction, which, according to its understanding, started from offenses punishable with imprisonment exceeding six (6) months.
The respondent court argued that jurisdiction over offenses with lower imposition of imprisonment belonged exclusively to the city (or municipal) courts.
The People moved for reconsideration of the dismissal, but the motion was denied on June 19, 1975.
Subsequently, the case was elevated to the Supreme Court through a petition for review on certiorari.

Whether the Court of First Instance had jurisdiction over the offense when the prescribed penalty provided by law included either imprisonment of six (6) months or a fine between P200.00 and P500.00.
Whether the presence of an alternative fine, which exceeds the P200.00 threshold, brings the case under the jurisdiction of the Court of First Instance despite the imprisonment term not exceeding six (6) months.

How to interpret Section 44(f) of the Judiciary Act of 1948, which assigns original jurisdiction to the Courts of First Instance in criminal cases where the penalty is imprisonment for more than six months or a fine above P200.00.
How Section 87(c) of the same Act, conferring original jurisdiction to municipal or city courts for certain offenses, interacts with Section 44(f), particularly in relation to penalties that fall in the concurrent jurisdiction zone.

Whether the principle of “first acquires jurisdiction” applies when two courts have concurrent jurisdiction over an offense.
Whether the initial filing of the case with the Court of First Instance validly vested it with jurisdiction to try the offense to the exclusion of the municipal or city courts.