Case Summary (G.R. No. L-3023)
Scope of appellate review from municipal and justice courts; finality of Court of First Instance judgments
The Court explained that where a criminal case originates in a justice or municipal court and is then tried and decided in the Court of First Instance on appeal, the judgment of the Court of First Instance is generally final and conclusive. The Supreme Court will not entertain a second appeal on factual or ordinary legal issues unless the appeal raises the constitutionality or validity of a statute. This procedural limitation preserves the finality of trial-court-of-record judgments, reserving Supreme Court review for matters implicating the legal validity of statutes or ordinances.
Role of assessors and due process claim
The Court addressed contentions concerning the role and opinions of assessors. It clarified that in criminal cases tried in the Court of First Instance with assessors (as provided under Act No. 267), the Supreme Court has the power to review all the evidence when it is passing upon such cases on appeal, whether or not the assessors agreed with the trial judge. However, where the case originated in a justice or municipal court and was heard in the Court of First Instance on appeal with assessors, the disagreement of the assessors with the judge’s decision is not, by itself, a ground for a second appeal to the Supreme Court. In appeals raising only the constitutionality or validity of a statute, the Supreme Court confined its review to that legal question and did not undertake to review the evidence or other factual matters, even if the assessors disagreed with the judgment below. The Court therefore overruled the motion for a new trial predicated on the assessors’ contrary opinion without prejudice to reconsideration if the Supreme Court were to review the appeal on its merits.
Legal basis for municipal authority and validity of Ordinance No. 28
On the substantive question of the ordinance’s validity, the Court held that Ordinance No. 28 was a municipal statute enacted under the legislative authority conferred upon the Municipal Board of the City of Manila by Act No. 183 (sections 16 and 17), which set forth the general and special powers of the municipality. The Court characterized an ordinance as a rule of conduct prescribed by municipal authorities that must be obeyed by citizens. It found no showing that the ordinance was not of a general character, that it was not based upon sound principles, that it did not affect citizens uniformly, or that it conflicted with any l
...continue readingCase Syllabus (G.R. No. L-3023)
Case Caption, Report Citation, and Author of Decision
- Reported as 7 Phil. 325, G.R. No. 3023, decided January 16, 1907.
- Caption: The United States, complainant and appellee vs. Pablo Trinidad, defendant and appellant.
- Opinion authored by Justice Torres (TORRES, J.).
- Concurrence recorded: Arellano, C.J., Carson, Willard, and Tracey, JJ., concur.
Facts of the Case
- Pablo Trinidad was charged, together with another person, with violation of a municipal ordinance under a charge of sodomy.
- Trinidad was originally tried and convicted in the municipal court of the city of Manila.
- Sentence in the municipal court: one month imprisonment and payment of a fine of P100 (Philippine currency).
Immediate Procedural History
- Trinidad appealed from the municipal court to the Court of First Instance (CFI).
- The CFI sustained the municipal court conviction and increased the penalty.
- CFI sentence: six months' imprisonment at hard labor and a fine of $100 (United States currency), plus costs of the proceedings.
- Counsel for the defendant appealed from the CFI judgment; the CFI allowed the appeal to this Court on the ground that the validity of Ordinance No. 28 of the city of Manila was involved.
Prior Related Proceedings and Authority Cited
- This Court had earlier decided (in the context of a demurrer by the Attorney-General to a complaint filed on behalf of John C. Sweeney, judge of the CFI, in a mandamus action) on May 1, 1905, key principles about appeals from justice/municipal courts.
- That prior decision stated a general rule that judgments of the Courts of First Instance are final in criminal cases on appeal from the justice court; that this rule applies to municipal court appeals unless the appeal involves constitutionality or legality of a statute.
- The May 1, 1905 decision emphasized that when appeal involves the validity of an ordinance, the Supreme Court will confine itself to the question of the ordinance's validity and will not review evidence or decide other questions of law arising from the evidence.
Legal Instruments and Provisions Referred To
- Ordinance under challenge: Ordinance No. 28 of the city of Manila (passed March 19, 1902; took effect April 2, 1902).
- Legislative authority cited for municipal action: Act No. 183, sections 16 and 17 (relating to general and special powers of the municipality of Manila) enacted by the Philippine Commission.
- Provision governing appeals from justice/municipal courts: section 43 of General Orders, No. 58.
- Statutory/administrative provision extending assessors to criminal cases: Act No. 267.
- This Court repeatedly references its prior decisions construing section 43 of General Orders No. 58.
Issues Presented to the Court
- Whether the appeal to this Court was properly allowed given that the CFI had entertained the appeal from the municipal court.
- Whether this Court, on the present appeal, may review evidence or other questions of law beyond the constitutionality or validity of the municipal ordinance.
- Whether Ordinance No. 28 of the city of Manila is valid and was lawfully enacted and enforceable.
- Whether the alleged failure of the CFI judge to consult with assessors (who had filed an opinion contrary to the judge’s decision) deprived the accused of due process and entitled him to a further appeal or new trial before this Court.
Court’s Analysis on Scope of Review and Right of Appeal
- Restates controlling principle: as a general rule the judgments of the Courts of First Instance are final in criminal cases on appeal from the justice or municipal courts.
- Exception: when appeal involves constitutionality or legality of a statute or or