Case Summary (G.R. No. L-47033)
Case Background
The petitioners, Generoso and Lamberto Castrodes, sought to annul the judgment of the municipal court convicting them of usurpation of real property. Generoso was fined P350 and served subsidiary imprisonment due to insolvency, while Lamberto received a more serious sentence of an indeterminate penalty for allegedly committing a complex crime involving usurpation of real property and grave threats. The critical incident occurred on July 10, 1975, concerning a land dispute with the Ampong family.
Jurisdictional Issues
The petitioners contended that the municipal court lacked jurisdiction over the penalties imposed, particularly in relation to the sentence of Lamberto. The Revised Penal Code specifies that usurpation of real property can be charged when accompanied by violence or intimidation. However, the court’s authority to impose sentences depends on the provisions of the Judiciary Law which stipulates that municipal courts can adjudicate offenses with penalties of up to three years of imprisonment or fines within specific limits.
Findings of the Municipal Court
The municipal court found the Castrodes brothers guilty of encroaching onto land owned by the Ampong family, establishing that Generoso was the half-brother of the Ampongs. It was determined that Lamberto's threats to Julian Ampong constituted intimidation but did not establish a separate offense of grave threats, being inherently part of the usurpation.
Legal Interpretation of Offenses
According to the Revised Penal Code, the offense of usurpation involves occupation of another's property through violence or intimidation, with an intent to gain. The court ruled that Lamberto's threat did not constitute a distinct crime of grave threats but rather served as the intimidation required for usurpation. Thus, the complaint filed charged only the single offense of usurpation of real property.
Conclusion and Ruling
The Supreme Court conclu
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Case Overview
- This case arises from a petition for certiorari filed on September 9, 1977, seeking to annul a judgment from the municipal court of Anda, Bohol, dated April 28, 1976.
- The petitioners are Generoso Castrodes and his son Lamberto Castrodes, who were convicted of usurpation of real property and grave threats.
- The primary contention revolves around the lack of jurisdiction of the municipal court over the penalties imposed.
Background of the Case
- Generoso Castrodes was convicted of usurpation of real property and sentenced to a fine of P350, with subsidiary imprisonment if unable to pay.
- Lamberto Castrodes was convicted of usurpation of real property and grave threats, receiving an indeterminate sentence ranging from four months and one day of arresto mayor to five years of prision correccional.
- Lamberto served his sentence at the New Bilibid Prison and was paroled on August 10, 1977.
Factual Allegations
- The Chief of Police of Anda, Bohol, filed a complaint against the petitioners, alleging that they unlawfully entered the land of the Ampong family and planted coconut trees without permission.
- The complaint details a confrontation where Lamberto threatened Julian Ampong, a member of the offended party, stating that blood would b