G.R. No. L-6641 - Quizon vs. Justice of the Peace of Bacolor, Pampanga

The Justice of the Peace Court lacks jurisdiction to try the offense of damage to property through reckless imprudence if the damage amounts to P125.
Jurisdiction over such cases lies with the Court of First Instance.
The relevant legal provisions include Section 44 of the Judiciary Act of 1948, which delineates the original jurisdiction of Courts of First Instance, and Section 87, which grants Justices of the Peace jurisdiction over specific criminal cases, including malicious mischief.

Damage to property through reckless negligence is not a variant of malicious mischief.
Malicious mischief, as defined in Article 327 of the Revised Penal Code, requires a willful and deliberate intent to cause damage.
The essence of malicious mischief is the specific intent to inflict injury, which is incompatible with the concept of negligence.

The Supreme Court of Spain has recognized that malicious mischief cannot be committed through negligence.
The Revised Penal Code treats criminal negligence as a separate quasi-offense, distinct from willful crimes.
The penalties for reckless imprudence are set independently of the penalties for willful offenses, indicating a clear legislative intent to differentiate between the two.

The Judiciary Act of 1948 created exceptions to the general jurisdiction of Justice of the Peace Courts, allowing them to try specific felonies, including malicious mischief.
Damage to property through negligence is not included in these exceptions, reinforcing the conclusion that jurisdiction lies exclusively with the Court of First Instance.

The Supreme Court concluded that the Justice of the Peace Court does not have jurisdiction over the offense of damage to property through reckless imprudence.
The writ of certiorari was granted, reversing the order of remand to the Justice of the Peace Court.