Case Summary (G.R. No. 203974)
Key Dates
• Charge filed: February 10, 1976
• Dismissal order by City Court judge: March 6, 1976 (with reiteration on April 1, 1976)
• Supreme Court decision: March 31, 1977
Applicable Legal Framework
• 1973 Philippine Constitution
• Republic Act No. 6591 (Sept. 30, 1972): Establishes Juvenile and Domestic Relations Courts (JDRCs) with jurisdiction over offenders under 16 at filing
• Presidential Decree No. 603 (June 11, 1975) – Child and Youth Welfare Code: Defines “youthful offender” as over nine but under 21 at offense commission
• Presidential Decree No. 798 (Sept. 11, 1975): Governs confinement of truants and out-of-school youths, specifying jurisdiction by age
Jurisdiction Under R.A. 6591
R.A. 6591 expressly confers on the Camarines Sur JDRC criminal jurisdiction only over those accused who are under 16 years of age at the time of case filing.
Definition Under P.D. 603
P.D. 603 introduces a broad definition of “youthful offender” (over nine but under 21 at commission), yet contains no express provision shifting jurisdiction of 16-to-under-21-year-olds from regular courts to Juvenile Courts.
Special vs. General Laws Doctrine
R.A. 6591 is a special law applying to the Camarines Sur JDRC; P.D. 603 is a general national statute. Under jurisprudence, a general law cannot repeal or modify a special law by implication.
Requirement of Express Repeal
The Child and Youth Welfare Code did not expressly amend or repeal R.A. 6591’s jurisdictional clause. By contrast, P.D. 603 explicitly repealed certain Civil Code provisions on adoption, demonstrating that express language is required for repeal or transfer of jurisdiction.
Reinforcement by P.D. 798
P.D. 798 confirms that applications concerning youths 16 to under 21 must be filed with regular Courts of First Instance, whereas only those under 16 fall under JDRC purview, thereby upholding the division established by R.A. 6591.
Limits on Judicial Expansion of Jurisdiction
Although the rehabilitative objectives of Juvenile Courts are acknowledged, policy considerations do not permit courts to expand their own special jurisdiction beyond clear legislative mandates.
Rehabilitative Measures for All Youthful Offenders
P.D. 603 centrally prescribes uniform procedures—physical and men
...continue readingCase Syllabus (G.R. No. 203974)
Facts of the Case
- Petitioner: People of the Philippines; Respondents: Hon. Judge Mericia B. Palma (City Court of Naga) and Romulo Intia y Morada (accused).
- On February 10, 1976, the Naga City fiscal’s office charged 17-year-old Romulo Intia y Morada with vagrancy under Article 202(2) of the Revised Penal Code.
- Respondent Judge Palma, presiding over the City Court of Naga, issued an order on March 6, 1976 dismissing the case for lack of jurisdiction, without prejudice to refiling in the Juvenile and Domestic Relations Court (JDRC).
- The Camarines Sur JDRC and the Solicitor General maintained that regular courts retain jurisdiction over accused persons aged 16 up to under 21, prompting this petition to resolve the conflict of jurisdiction.
Legal Issue
- Whether the issuance of Presidential Decree No. 603 (Child and Youth Welfare Code) — defining “youthful offender” as one over nine but under 21 years at the time of the offense — implicitly transferred criminal jurisdiction over 16- to under 21-year-old accused from regular courts (e.g., the City Court of Naga) to the Juvenile and Domestic Relations Courts.
Relevant Statutory Provisions
- Republic Act No. 6591 (effective September 30, 1972): Creates the Camarines Sur Juvenile and Domestic Relations Court and grants it jurisdiction over criminal cases where the accused is under 16 years of age at the time of filing.
- P.D. 6