No. 46896 - Pueblo de Filipinas vs. Pablo San Juan y Monterosa

The accused, Pablo San Juan y Monterosa, was charged in the Juzgado Municipal de Manila for the crime of theft.
The stolen property involved five (5) sacks of rice valued at P32.

The accused was initially tried and convicted in the Municipal Court of Manila.
He was sentenced to a principal penalty of 6 months of arresto mayor.
In addition, he was ordered to indemnify the victim with the sum of P32.
An additional penalty was imposed: 7 years, 4 months, and 1 day of prision mayor for being classified as a habitual delinquent.
The court also ordered the payment of court costs.

The accused appealed to the Juzgado de Primera Instancia de Manila where he was again found guilty and sentenced to the same penalties.
Upon further appeal to this Court, the appellant raised two main arguments of error in the lower court’s decision.

First, it was contended that the penalty for the crime of theft should have been imposed in its medium degree (arresto mayor from two months and one day to four months), based on the absence of any proven mitigating or aggravating circumstances during the commission of the theft.
Second, the appellant argued that the additional penalty of 7 years, 4 months, and 1 day imposed for habitual delinquency was illegal because the Municipal Court of Manila allegedly lacked jurisdiction to impose such a penalty under the circumstances.

The appellant cited the case of Pueblo de Filipinas contra Liberato del Mundo (R.G. No. 46531) and pointed to the earlier decision in Pueblo de Filipinas contra Jesus Acha y Rivera (R.G. No. 46714), which clarified that the jurisdiction of the Municipal Court in cases of theft is determined by the monetary value of the stolen property, not by the severity of the penalty.
It was noted that when the value of the stolen property does not exceed P200, the Municipal Court has jurisdiction regardless of the penalty provided by law.

The appellant also contended that his participation in the commission of the theft—of which he had previously been convicted—was limited to that of an encubridor (accomplice) rather than as an actual author of the crime.
Based on this, he argued that the application of the habitual delinquency principle should not include his prior conviction.

Whether, in the absence of any substantial mitigating evidence, the principal penalty of arresto mayor should have been reduced to its medium degree (from two months and one day to four months) instead of being imposed at its maximum.

Whether the Municipal Court of Manila had the proper jurisdiction to impose the additional penalty of 7 years, 4 months, and 1 day of prision mayor on the ground of habitual delinquency.
Whether the prior involvement as an encubridor, rather than as an author, negates the classification of the accused as a habitual delinquent.

Whether the precedents cited (Pueblo de Filipinas contra Liberato del Mundo and Pueblo de Filipinas contra Jesus Acha y Rivera) sufficiently support the appropriate exercise of jurisdiction by the Municipal Court despite the imposition of an additional penalty.