Case Summary (G.R. No. 157384)
Facts of the Case
The issue arose from the filing of an information in the Circuit Criminal Court in Cagayan de Oro, accusing Paraguya of accepting a bribe of Three Hundred Pesos on October 10, 1968, in his capacity as a public officer. Paraguya moved to quash the information on grounds of lack of jurisdiction, asserting that indirect bribery does not fall within the jurisdiction of the Circuit Criminal Court as defined by Republic Act 5179.
Jurisdictional Issues
Paraguya contended that Republic Act 5179 grants Circuit Criminal Courts concurrent jurisdiction with courts of first instance only over crimes falling within their original and exclusive jurisdiction. He argued that since the crime of indirect bribery, under Article 211 of the Revised Penal Code, is associated with penalties that can also be resolved by city or municipal courts, it falls outside the purview of the Circuit Criminal Court.
Court's Orders and Petition for Certiorari
The Circuit Judge denied Paraguya's motion to quash, leading to a petition for certiorari to nullify the court's orders, as they were deemed to be issued in excess or without jurisdiction. The Supreme Court granted a writ of preliminary injunction, restraining the respondent judge from proceeding with the case while the petition was under deliberation.
Legal Basis and Ruling
The Supreme Court's analysis hinged on the jurisdictional limits set forth in Republic Act 5179. It clarified that Circuit Criminal Courts, created to expedite the resolution of specific criminal cases, have limited jurisdiction that only encompasses crimes explicitly enumerated in the law, particularly those with penalties exceeding three years imprisonment or substantial fines. Indirec
...continue readingCase Syllabus (G.R. No. 157384)
Background of the Case
- The case concerns an original petition for certiorari questioning the jurisdiction of the Circuit Criminal Court regarding a charge of indirect bribery against Pacianito S. Paraguya, an internal revenue examiner.
- The information filed in the Circuit Criminal Court alleged that on October 10, 1968, Paraguya, while acting in his capacity as a public officer, unlawfully solicited and received a sum of Three Hundred Pesos from Sia Bon Suan, a stockholder and manager of a local cockpit.
- The petitioner filed a motion to quash the information, arguing that the Circuit Criminal Court lacked jurisdiction over the case.
Legal Arguments Presented
- Paraguya contended that Republic Act 5179, which established the Circuit Criminal Courts, limited their jurisdiction to certain crimes that fall under the exclusive jurisdiction of courts of first instance.
- As the penalties for indirect bribery, as outlined in Article 211 of the Revised Penal Code, included arresto mayor (imprisonment not exceeding six months), suspension, and public censure, he argued that these penalties could also be imposed by city or municipal courts.
- Consequently, he asserted that the Circuit Criminal Court did not possess the jurisdiction to hear the case.
Court's Initial Rulings
- The Circuit Judge denied the motion to quash on January 23, 1969, citing lac