Case Summary (G.R. No. L-37446)
Summary of Proceedings
Following the collision, a criminal charge was filed on April 27, 1971, against Arcaya and Ceballos for "double less serious physical injuries, slight physical injuries and damage to property thru reckless imprudence" in Criminal Case No. 1397. The offenses involved injuries to various parties, including passengers of Dr. Nazareno’s Combi. The initial complaint faced a motion to quash from the defendants, asserting the improper joinder of offenses. Consequently, the Chief of Police amended the complaints on July 9, 1971, to separate the less serious injuries from the slight injuries, reorganizing the cases accordingly.
Jurisdictional Issues
Arcaya and Ceballos continued to contest the municipal court's jurisdiction, arguing that the offenses could not be joined in one indictment and that the slight physical injury charge had already prescribed. The municipal court denied their motion to quash, leading the petitioners to escalate the matter to the Court of First Instance of Bohol through a special civil action for certiorari and prohibition, which was dismissed on April 12, 1973. Subsequently, the petitioners sought further review of this dismissal by filing for certiorari, prohibition, and mandamus in a higher court.
Misapprehension of Jurisdiction
The court highlighted that the assertion that the complaint "conferred jurisdiction" is a fundamental misunderstanding. Jurisdiction derives from law, not from the complaint itself. It was noted that the municipal court of Tubigon possessed the requisite authority to handle the offenses charged under the pertinent provisions of the Judiciary Law. Furthermore, the prescription issue, deemed a non-jurisdictional matter, had been properly characterized, as the clock on prescription is interrupted by the filing of the original complaint.
Denial of Certiorari
It was determined that the lower courts did not act in excess of their jurisdiction nor did they grossly abuse their discretion, validating their denial of the motion to quash. Certiorari is intended to address grave abuses of discretion or jurisdictional errors—not errors in judgment, which are correctable through appeal. This aligns with established legal principles, wherein issues arising from procedural errors or erroneous findings do not war
...continue readingCase Syllabus (G.R. No. L-37446)
Case Background
- On March 1, 1971, a vehicular collision occurred in Tubigon, Bohol, involving a jeep owned by the Tagbilaran Branch of the Philippine National Bank (PNB) and a Volkswagen Combi owned by Doctor Domiciano Nazareno.
- Emmanuel Ceballos was allegedly driving the jeep at the time of the accident, having been permitted by Reno Arcaya, the regular driver of the jeep, both of whom were PNB employees.
- The collision resulted in injuries to the passengers of the Combi and damages to both vehicles.
- The offended parties included Doctor Remedios N. Relampagos, Paz F. Nazareno, and minor Mary Carlyn Relampagos, who suffered various degrees of physical injuries.
Legal Proceedings Initiated
- On April 27, 1971, the Chief of Police of Tubigon filed charges against Arcaya and Ceballos in the municipal court for "double less serious physical injuries, slight physical injuries and damage to property through reckless imprudence" (Criminal Case No. 1397).
- The Chief of Police filed two amended complaints on July 9, 1971, separating the charges into:
- Less serious physical injuries and damage to property (Criminal Case No. 1397).
- Slight physical injuries (Criminal Case No. 1397-A).
Motion to Quash
- Arcaya and Ceballos, through counsel Manuel Estimo, moved to quash the complaints, arguing that the offenses charged could not be joined in a single indictment.
- The municipal court denied their motion to quash, leading them to file actions of certior