People v. Blanco
REITERATIONFacts
The Antecedents: On September 28, 1948, an information was filed in the municipal court of Iloilo charging Claudio Galicto and Roberto Sevilla with theft of two trousers valued at P28.00. The information also alleged that the accused were habitual delinquents, having been convicted of theft on three previous occasions. Procedural History: Claudio Galicto pleaded guilty. The municipal judge, believing he lacked jurisdiction, forwarded the case to the Court of First Instance (CFI). In the CFI, the fiscal moved for the return of the case, arguing the municipal court had jurisdiction. The CFI, presided over by respondent judge, denied the motion and a subsequent motion for reconsideration. The Petition: The People of the Philippines filed a petition for certiorari and mandamus seeking to prohibit the respondent judge from taking cognizance of the case and to have it returned to the municipal court.
Issue(s)
Whether the municipal court of Iloilo had jurisdiction over the theft case despite the accused's habitual delinquency. Whether the Court of First Instance should retain jurisdiction over the case since the records were already transmitted to it.
Ruling
The petition for certiorari and mandamus is granted. The respondent judge is prohibited from taking cognizance of the case, which must be returned to the municipal court of Iloilo for further proceedings.
Ratio Decidendi
On the jurisdiction of the municipal court: The Court held that the character of the City of Iloilo provides that its municipal court has concurrent jurisdiction with the Court of First Instance over cases of larceny, embezzlement, and estafa where the value of the property does not exceed two hundred pesos. In this case, the theft involved property worth only P28.00, thus falling within the municipal court's jurisdiction. The Court clarified that the jurisdiction of such municipal courts, unlike ordinary justice of the peace courts, is determined by the value of the property stolen or embezzled, not by the extent of the penalty that might be imposed due to habitual delinquency. It was reiterated that habitual delinquency is not a crime in itself but a factor in determining the total penalty, as provided by Article 62 of the Revised Penal Code. Therefore, the municipal court correctly had jurisdiction over the offense charged. On the retention of jurisdiction by the Court of First Instance: The Court rejected the suggestion that the case should remain with the Court of First Instance in the interest of speedy adjudication, citing the rule that where several courts have concurrent jurisdiction, the court which first acquires jurisdiction retains it to the exclusion of others. Allowing the CFI to retain jurisdiction, even with concurrent powers, could lead to jurisdictional challenges raised by the accused himself. Consequently, the principle of first acquisition of jurisdiction dictated that the municipal court, having initially taken cognizance of the case, should retain it.
Main Doctrine
The jurisdiction of a municipal court in theft cases, similar to that of Manila, is determined by the value of the property stolen, not by the penalty imposable due to habitual delinquency. Where several courts have concurrent jurisdiction, the court that first acquires jurisdiction retains it.