Title
People vs. Buissan
Case
G.R. No. L-54419
Decision Date
Jul 15, 1981
A 1979 case involving simple seduction charges against Paterno Santiago, where the Supreme Court ruled that the Court of First Instance retains jurisdiction due to accessory civil liabilities, despite the penalty falling under municipal court jurisdiction.

Case Summary (G.R. No. L-44640)

Procedural History

Information for simple seduction was filed and docketed as Criminal Case No. 2258. Arraignment took place and the accused pleaded not guilty. The accused moved to quash the information for failure to allege lewd design and filed a formal motion to quash/dismiss. The Court of First Instance Judge Buissan denied the motion to quash but remanded the case to the City Court of Dapitan on the ground that the penalty for simple seduction is arresto mayor and thus within the inferior court’s jurisdiction. The People moved for reconsideration, which was denied. The City Judge Martinez assumed jurisdiction and set the case for trial on the merits. The People petitioned the Supreme Court for certiorari, prohibition, and mandamus alleging grave abuse of discretion by both judges in placing the case in the City Court, and sought preliminary injunction; all respondents filed answers.

Issue Presented

Whether a criminal case charging simple seduction, which under the penal provision carries a penalty of arresto mayor (imprisonment not exceeding six months), falls under the exclusive original jurisdiction of a municipal or city (inferior) court, or whether it falls within the original jurisdiction of the Court of First Instance by reason of attendant accessory civil liabilities (acknowledgement and support of offspring, indemnification) that are beyond the competence of inferior courts.

Relevant Precedents and Doctrinal Basis

The Court relied principally on earlier rulings that addressed the same jurisdictional question. U.S. v. Bernardo (19 Phil. 265) established that a justice of the peace lacked jurisdiction over simple seduction where attendant civil recognition/support issues were involved. Luansing v. People (27 SCRA 308, 1969), by an undivided court, reaffirmed Bernardo and analyzed the interplay of RA 296 jurisdictional provisions: although Article 338’s penalty (arresto mayor) would ordinarily place simple seduction within municipal court jurisdiction, Article 345’s accessory civil liabilities (acknowledgment and support of offspring, indemnification) are matters within the original jurisdiction of the Court of First Instance (Section 44(a) and (e), RA 296). The Luansing decision applied doctrines permitting a superior court to take cognizance of connected matters that would otherwise fall within inferior court jurisdiction to avoid fragmentation and duplicative proceedings (citing analogous precedents such as Fireman’s Fund Insurance Co. v. Cia. General de Tabacos de Filipinas). The Court also cited authorities emphasizing that jurisdiction is to be determined from the complaint or information’s recited facts and the penalties/obligations prescribed by law, not by evidence developed at trial or the ultimate sentence to be imposed (People v. Cuello; People v. Co Hiok; People v. Purisima; People v. Mission).

Court’s Analysis on Jurisdictional Principle

The Court reaffirmed the Bernardo/Luansing doctrine: where a penal statute prescribes both a specific criminal penalty within the competence of inferior courts and accessory civil obligations that lie exclusively within the original jurisdiction of the Court of First Instance, the latter court has original jurisdiction over the entire case to permit adjudication of all connected issues in one proceeding. The Court reasoned that it would be impractical and inefficient to have the principal criminal charge tried in a municipal or city court and then require subsequent proceedings in the Court of First Instance solely to resolve acknowledgment and support of offspring — a duplication of proceedings prejudicial to orderly administration of justice. The Court emphasized that the determination of jurisdiction depends on the nature of the offense as described in the information and the legal consequences attendant thereto, not on factual results that may emerge at trial or the length of punishment ultimately imposed.

Application to the Present Case

Applying the stated doctrine to the facts recited in the information — an allegation of simple seduction resulting in pregnanc

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