Case Summary (G.R. No. L-8169)
Factual Background
The provincial fiscal of Bukidnon filed an information on October 13, 1977, charging the Marapao respondents with serious physical injuries against Mrs. Lolita Ares, a mother who had recently given birth. The accusation specifies acts of violence, including throwing a fist-sized stone that resulted in significant injury to Ares' face and subsequent incapacity for over thirty days. The charge invoked Article 263, paragraph 3 of the Revised Penal Code.
Jurisdictional Issues Raised by the Respondent Judge
The respondent judge, after reviewing the records, dismissed the case on October 27, 1977, asserting a lack of jurisdiction, suggesting that the medical certificate indicating the need for treatment for 7 to 10 days categorized the injuries as slight or less serious, which falls outside his court's authority. The judge erroneously determined that the physical injury case should depend solely on the medical certificate rather than the victim's statements.
Examination of Judicial Conduct and Abuse of Discretion
The judge's ruling was deemed a grave abuse of discretion since it was premature. He dismissed the case without allowing for an arraignment or a proper trial, nor did he consider the testimonies of the parties involved, particularly that of the physician who provided the medical certificate. His assessment based on the contents of the certificate, in isolation, disregarded crucial evidence supporting the claim of serious injury.
Application of Established Legal Principles
The Court emphasized that jurisdiction in criminal cases is governed by the allegations contained in the information and not by preliminary evidence or personal evaluations by the judge. It cited that once jurisdiction is established based on the initial filing, it cannot be negated by subsequent evidence that might suggest a lesser charge. Therefore, the initial jurisdiction remains intact, allowing the trial court to deal with evidence presented at trial.
Implications and Transfer of Case
Given the respondent judge's apparent bias and inability to impartially adjudicate the matter, the Court found it necessary
...continue readingCase Syllabus (G.R. No. L-8169)
Background and Factual Context of the Case
- The case arose from an information filed by the provincial fiscal of Bukidnon on October 13, 1977, charging the three private respondents—Esterlina Marapao, Leticia Marapao, and Diosdado Marapao—with the crime of serious physical injuries.
- The crime was alleged to have been committed on or about July 23, 1977, in Don Carlos, Bukidnon, within the jurisdiction of the respondent judge’s court.
- The accusation entailed a concerted attack upon Mrs. Lolita Ares, a mother twelve days post-childbirth, involving her being wrestled to the ground and struck on the face with a fist-sized stone.
- The injuries as detailed in the information included a lacerated wound measuring approximately 2.5 cm by 0.5 cm on the maxillary arch of the face, accompanied by contusion and swelling, causing a considerable facial deformation.
- Additionally, the victim suffered a relapse attributable to her weak constitution postpartum, leading to incapacitation from customary labor for more than thirty days.
- The offense was charged under Article 263, paragraph 3 of the Revised Penal Code.
Proceedings and Orders of the Respondent Judge
- No arraignment or trial on the merits took place, nor were arrest warrants issued prior to the judge’s intervention.
- Respondent judge, upon reviewing the records and the attached medical certificate reporting a treatment duration of 7 to 10 days, concluded that the injuries were slight or less serious physical injuries.
- The judge summarily dismissed the information on October 27, 1977, citing lack of jurisdiction on the premise that the crime charged was not within his court’s jurisdiction.
- He stated that the controlling factor in assessing physical injury cases is the physician’s medical certificate regarding treatment duration, rather than the victim's affidavit, which he deemed self-serving.
- The provincial fiscal’s motion for reconsideration was denied by the judge on November 16, 1977, whereby the judge further discredited the existence of the alleged facial deformity based on an erroneous interpretation of discrepancies between the medical certificate and the fiscal’s observations.
- The judge’s decisions were issued without hearing parties or their witnesses, including the physician who issued the medical certificate.
Legal Issues Presented
- Whether the respondent judge rightfully dismissed the information for lack of jurisdiction based on his evaluation of the injuries.
- Whether juris