G.R. No. L-49834 - Soriano vs. Court of Appeals

On December 19, 1952, the respondent Chief of Police of Bacolor, Pampanga, filed a criminal complaint against Francisco Quizon.
The charge was for damage to property through reckless imprudence, with the damage valued at P125.00.
The criminal complaint was filed before the Justice of the Peace Court of Bacolor, Pampanga.

Quizon filed a motion to quash the complaint arguing that under Article 365 of the Revised Penal Code, the penalty for the offense (a fine from P125.00 to P375.00) exceeded the monetary limit that a Justice of the Peace Court could impose.
This raised the issue of whether the jurisdiction of the Justice of the Peace Court extended to such cases, given the statutory limitations.

The Justice of the Peace Court forwarded the case to the Court of First Instance (CFI) of Pampanga.
The CFI, however, returned the case to the Justice of the Peace Court for trial on the merits, asserting that jurisdiction was proper in the lower court.
Quizon appealed the CFI ruling to the Supreme Court, challenging the jurisdictional basis on the question of law.

Section 44 of the Judiciary Act of 1948 (Republic Act No. 296) is cited, which grants original jurisdiction to the Courts of First Instance for criminal cases where the penalty exceeds six months’ imprisonment or a fine of more than P200.00.
Section 87 of the same Act assigns original jurisdiction to Justices of the Peace and municipal judges over criminal cases arising under laws related to "malicious mischief."
Jurisprudence had established that in cases of malicious mischief, jurisdiction is concurrent when the penalty exceeds the limits applicable to Justices of the Peace.

The case centered on whether damage to property committed through reckless negligence (as charged under Article 365) should be categorised as malicious mischief.
The essence of malicious mischief involves an element of deliberate intent or malice, as required by Article 327 of the Revised Penal Code.
It was explained that malicious mischief cannot result from negligence, as negligence (culpa) and malice (dolo) are incompatible.
Prior decisions (e.g., People vs. Palmon; People vs. Penas y Ferrer and Key y Rochas; Natividad et al. vs. Robles) supported the view that when the penalty extends beyond the Justice of the Peace’s limit, the case must be tried by the CFI.

Held that the offense charged under Article 365 (damage to property through reckless imprudence) lacked the special malice required for malicious mischief.
Concluded that the statutory limits set for penalties in reckless imprudence (fine ranging from the value of damage to three times that value) meant that, in this instance (P375.00 being the upper range), the Justice of the Peace did not have jurisdiction.
Thus, the jurisdiction over the offense lies exclusively with the Court of First Instance.

One concurring judge noted that although both forms of the offense involve property damage, the law clearly distinguishes between willful malicious mischief and mere negligence.
Another concurring opinion emphasized applying the law as written even if its rationale might be questioned.

The dissent argued that the crime of damage to property through reckless negligence should be considered a valid offense under the Revised Penal Code.
It urged against the narrow construction that limits liability to cases with deliberate malice, asserting that negligence can also constitute a punishable felonious act.

Does the Justice of the Peace Court have concurrent jurisdiction with the Court of First Instance over cases involving damage to property through reckless negligence when the damage amount is P125.00?
Is the offense committed by Francisco Quizon—a case of damage through reckless imprudence—sufficiently akin to malicious mischief to justify the jurisdiction of the Justice of the Peace Court?

Should damage to property through reckless imprudence be treated as a mere variant of malicious mischief, thereby falling within the jurisdiction granted to Justices of the Peace?
How do the elements of malice versus negligence affect the classification and subsequent court jurisdiction in criminal cases?

What is the effect of the statutory ceiling (i.e., fine not exceeding P200.00) imposed on Justices of the Peace on cases where the penalty prescribed under Article 365 exceeds that limit?
Does the structure of penalties for reckless imprudence disqualify the Justice of the Peace Court from trying such cases?