Case Summary (G.R. No. 157900)
Petitioner
People of the Philippines, by the City Fiscal and Assistant City Fiscal of Roxas City.
Respondents
Libertad Lagon and Hon. Judge Isidro O. Barrios.
Key Dates
– April 5, 1975: Alleged issuance of a bouncing check by Lagon.
– July 7, 1976: Filing of Criminal Case No. 7362 in the City Court of Roxas City.
– December 2, 1976: Order dismissing the information for lack of jurisdiction.
– May 18, 1990: Supreme Court resolution denying the petition for review.
Applicable Law
– 1987 Philippine Constitution (governing judicial authority post-1987).
– Judiciary Act of 1948, Section 87 (subject-matter jurisdiction of city courts).
– Revised Penal Code, Article 315(2)(d) (estafa by issuing bad checks).
– Presidential Decree No. 818 (increasing penalties for check-related estafa, effective October 22, 1975).
Procedural History
A criminal information for estafa under Art. 315(2)(d) was filed against Lagon in July 1976. The City Court dismissed the case, holding that the amended penalty exceeded its jurisdictional limit. The People sought review, contending that the City Court retained jurisdiction because the offense occurred before the penalty enhancement.
Issue
Whether the City Court of Roxas City had subject-matter jurisdiction over the amended penalty for estafa at the time the information was filed.
Ruling
The Supreme Court affirmed the dismissal, ruling that jurisdiction is measured by the law in force at the commencement of the criminal action.
Reasoning
- Under Section 87 of the Judiciary Act of 1948, city courts may try offenses punishable by up to prision correccional or a ₱6,000 fine.
- At the time of commission (April 1975), the maximum penalty for estafa by bounced check was within city court jurisdiction.
- By July 1976, P.D. No. 818 had elevated the penalty to prision mayor in its medium period, exceeding city court authority.
- Jurisdiction in criminal cases is determined by the penalty prescribed at the time of filing, not by the date of the offense.
- The rule against ret
Case Syllabus (G.R. No. 157900)
Facts of the Case
- On April 5, 1975, Libertad Lagon allegedly issued a bouncing check in the amount of ₱4,232.80 for the purchase of goods, fully aware that she lacked sufficient funds to cover it.
- On July 7, 1976, a criminal information for estafa under paragraph 2(d), Article 315 of the Revised Penal Code was filed in the City Court of Roxas City and docketed as Criminal Case No. 7362.
- The prosecution commenced presentation of evidence against private respondent Libertad Lagon.
Procedural History
- December 2, 1976: The City Court of Roxas City dismissed the information on the ground that the penalty then prescribed exceeded the court’s jurisdictional authority.
- The City Court held that jurisdiction must be measured by the law in force at the time the action is instituted, not at the time of the offense.
- The dismissal was without prejudice to refiling in the proper court.
- The People of the Philippines filed a Petition for Review before the Supreme Court, contending that the City Court had proper jurisdiction and erred in dismissing the case.
- The Supreme Court referred the petition to the Office of the Solicitor General (OSG) for comment. The acting Solicitor General supported the City Fiscal’s view that the City Court had jurisdiction.
Issue
- Whether the City Court of Roxas City committed reversible error in dismissing Criminal Case No. 7362 for lack of subject-matter jurisdiction, considering (a) the law in effect at the time of the offense; (b) the law in effect at the time of the institution of the prosecution; and (c) the rule against retroactivity of penal laws.