Case Digest (G.R. No. L-6641)
Facts:
Francisco Quizon v. The Hon. Justice of the Peace of Bacolor, Pampanga, et al., G.R. No. L-6641, July 28, 1955, the Supreme Court, Reyes, J.B.L., J., writing for the Court.Petitioner Francisco Quizon was charged by the respondent Chief of Police of Bacolor, Pampanga, before the Justice of the Peace of Bacolor on December 19, 1952, with the crime of damage to property through reckless imprudence; the value of the damage was alleged to be P125.00. Quizon filed a motion to quash the complaint, contending that under Article 365 of the Revised Penal Code the penalty that might be imposed (a fine of from the value of the damage to three times such value) could exceed the maximum fine that a justice of the peace may impose.
The Justice of the Peace forwarded the case to the Court of First Instance (CFI) of Pampanga for determination of jurisdiction. The CFI ruled that the Justice of the Peace had jurisdiction and remanded the case for trial before the latter. Quizon appealed that jurisdictional ruling to the Supreme Court, raising the legal question whether a Justice of the Peace court had jurisdiction to try an offense of damage to property through reckless imprudence where the damage amounted to P125.00.
In the Supreme Court the parties argued statutory construction of the Judiciary Act of 1948 (Republic Act No. 296), particularly Section 44(f) (original jurisdiction of Courts of First Instance) and Section 87(c)(6) (original jurisdiction of Justices of the Peace over, inter alia, malicious mischief), and the relationship between the crime of malicious mischief (Arts. 327–331...(Pro-only)
Issues:
- Does the Justice of the Peace court have jurisdiction, concurrent with the Court of First Instance, to try the offense of damage to property through reckless imprudence when the damage amounts to P125.00?
- Does the term "malicious mischief" in Section 87(c)(6) of the Judiciary Act include offenses committed through reckless imprudence (culpa), or does it refer exclusively to wilful malicious m...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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