Facts:

• On December 19, 1952, a criminal complaint was filed against Francisco Quizon by the Chief of Police of Bacolor, Pampanga.
• The complaint charged Quizon with damage to property through reckless imprudence, with damages valued at P125.00.
• Quizon filed a motion to quash the complaint, arguing that the potential penalty exceeded the jurisdictional limit of the Justice of the Peace Court.
• The Justice of the Peace Court forwarded the case to the Court of First Instance of Pampanga, which returned it for trial, asserting jurisdiction.
• Quizon appealed to the Supreme Court, questioning the jurisdiction of the Justice of the Peace Court.

Issue:

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Ruling:

• The Supreme Court ruled that the Justice of the Peace Court does not have jurisdiction to try cases of damage to property through reckless imprudence when the damage is valued at P125.00.
• The Court granted the writ of certiorari, reversed ...(Unlock)

Ratio:

• The decision was based on the interpretation of the Judiciary Act of 1948, particularly Section 44, which outlines the original jurisdiction of Courts of First Instance.
• The Court noted that Justices of the Peace have concurrent jurisdiction with Courts of First Instance only in specific cases, such as malicious mischief under Article 327 of the Revised Penal Code.
• Malicious mischief involves specific intent to cause harm, unlike reckless imprudence, which occurs without intent.
• The Court clarified that the natur...continue reading