People v. Santos
REITERATIONFacts
The Antecedents: The accused was charged with attempted bribery for allegedly offering and delivering one (1) peso bill to a member of the police force of the City of Manila. The purpose was to induce the patrolman to abstain from performing his duty, specifically to arrest the accused and file a charge for obstruction of a public street. Procedural History: The Court of First Instance of Manila dismissed the criminal case on the ground that the offense alleged in the information was beyond its jurisdiction. The Petition: The People of the Philippines appealed the dismissal order of the Court of First Instance.
Issue(s)
Whether the Court of First Instance has jurisdiction over a criminal case for attempted bribery when the imposable penalty for the said stage of the crime is destierro.
Ruling
The appealed order of the Court of First Instance of Manila dismissing the criminal case is affirmed without special findings as to costs.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Court of First Instance (CFI) does not have jurisdiction over the crime of attempted bribery because the penalty involved falls within the jurisdiction of lower courts. Applying the precedent in Uy Chin Hua vs. Hon. Judge Rafael Dinglasan (86 Phil., 617), the Court noted that the penalty for the consummated crime of bribery is arresto mayor in its medium and maximum periods. Under the graduated scales of the Revised Penal Code, the penalty for an attempted crime is two degrees lower than that of the consummated crime. This reduces the penalty for attempted bribery to destierro in its minimum and medium periods. The Court reaffirmed the doctrine that offenses penalized by destierro are under the jurisdiction of the justice of the peace and municipal courts. Therefore, the CFI correctly dismissed the information for lack of jurisdiction as the law assigns such penalties to the lower courts.
Main Doctrine
Offenses penalized by destierro fall under the jurisdiction of justice of the peace and municipal courts.