IN RE: Appeals from the People's Court

Jurisdictional Questions Post-Creation of the Court of Appeals

The primary issue addressed is whether the treason cases, previously under appeal to the Supreme Court, should remain with that court or be transferred to the newly re-created Court of Appeals. After the dissolution of the Court of Appeals in 1945 and the enactment of Commonwealth Act No. 682, treason cases were appealable directly to the Supreme Court, as the Court of Appeals did not exist at the time.

Legislative Framework Establishing Court Jurisdictions

As provided in Commonwealth Act No. 682, the People's Court had jurisdiction over treason cases and any related crimes, with decisions subject to review by the Supreme Court. The re-establishment of the Court of Appeals through Republic Act No. 52 on October 4, 1946, shifted appellate jurisdiction back to that court for all cases that did not fall under the Supreme Court’s exclusive appellate jurisdiction.

Judiciary Act of 1948 and Its Implications

The Judiciary Act of 1948 reaffirmed this jurisdictional framework, granting the Supreme Court exclusive appellate jurisdiction over cases involving death or life imprisonment penalties. Conversely, the Court of Appeals acquired jurisdiction over all other cases. The Supreme Court is mandated to certify cases to the appropriate court, in this instance, the Court of Appeals, as all cases falling under its exclusive appellate jurisdiction must be resolved there.

Analysis of Exclusive Appellate Jurisdiction

The decision emphasizes that the cases in question pertain to treason but do not invoke penalties that place them within the exclusive jurisdiction of the Supreme Court. Hence, the transfer of these cases to the Court of Appeals aligns with clear legislative intent and jurisdictional boundaries established by the 1948 Act.

Status of the People’s Court Relative to Courts of First Instance

The resolution establishes that while the People's Court previously operated with special jurisdiction, it should now be viewed analogously to a Court of First Instance in terms of jurisdictional hierarchy. This classification clarifies that any ongoing or previously resolved cases in the People's Court, abolished by Act No. 311, should revert to the Court of First Instance jurisdictions, thereby confirming the appellate paths outlined in existing laws.

Dissenting Opinions and Their Legal Basis

Dissenting Justices Feria and Moran argue against the majority stance, contending that the Supreme Court should retain jurisdiction over these treason cases based on the statutory original intentions of Commonwealth Act No. 682 and the legislative history surrounding Act No. 311. They maintain that the importance of having appellate oversight, particularly in treason cases, should not be undermined by jurisdictional shifts prompted by the re-creation of the Court of Appeals.

Legislative Intent and Historical Context

The dissent highlights that the legislative history an