People v. Rada
REITERATIONFacts
The Antecedents: On March 12, 1958, Lucio Rada, Pedro Bahenting, and Paquito Canas were charged with robbery in an uninhabited house under Article 302 of the Revised Penal Code. The information alleged that on July 17, 1957, in Davao City, the accused conspired to forcibly enter a bodega owned by Isidro S. Bastida by removing its wooden sidings. Once inside, they stole nine (9) sacks of palay valued at P108.00, with the aggravating circumstance of nighttime. Procedural History: The defendants pleaded not guilty. On August 4, 1958, they filed a motion to quash the information, arguing that the crime committed, given the value of the stolen property, fell under Article 303 of the Revised Penal Code, which is within the original jurisdiction of the Justice of the Peace Court. The prosecution opposed the motion. On September 15, 1958, the Court of First Instance granted the motion to quash, holding that palay is a cereal and thus the case falls under Article 303, making it cognizable by the inferior court. The case was dismissed, and the accused were ordered released or their bail cancelled. The Petition: The People of the Philippines, through the Solicitor General, appealed the order of dismissal to the Supreme Court.
Issue(s)
Whether palay is comprehended by the term "cereals" used in Article 303 of the Revised Penal Code. Whether the crime charged, robbery of palay valued at P108.00, falls under Article 303 of the Revised Penal Code, thereby placing it within the jurisdiction of the Justice of the Peace Court.
Ruling
The Supreme Court affirmed the order of the trial court granting the motion to quash, holding that the offense charged properly comes under Article 303 of the Revised Penal Code and is therefore within the original jurisdiction of the Justice of the Peace or Municipal Court.
Ratio Decidendi
On the issue of whether palay is comprehended by the term "cereals" used in Article 303 of the Revised Penal Code: The Court held that palay, being unhulled rice and a grain in its original state, is included in the term "cereal" or "semilla alimenticia" as used in Article 303 of the Revised Penal Code. The Spanish text of the Revised Penal Code uses "semilla alimenticia," which has a broader meaning than the English translation "cereal." "Semilla" refers to a part of the fruit of a plant that produces it when it germinates. Palay fits this definition as it is a seed that can germinate under proper conditions. The Court referenced People v. Mesias (65 Phil. 267) which stated that the term "rice" includes "palay" as the local name for the seed. Therefore, palay is considered a cereal for the purposes of Article 303. On the issue of whether the crime charged falls under Article 303 of the Revised Penal Code, thereby placing it within the jurisdiction of the Justice of the Peace Court: The Court ruled that since palay is considered a cereal under Article 303, the crime of robbery consisting of the taking of palay falls under this article. Article 303 provides that when the robbery consists in the taking of cereals, the culprit shall suffer the penalty next lower in degree than that prescribed in Articles 299 and 302. For robbery in an uninhabited house under Article 302, the penalty is arresto mayor in its maximum degree to prision correccional in its minimum degree. The next lower penalty would be arresto mayor in its minimum and medium periods. This penalty corresponds to an offense within the original jurisdiction of the Justice of the Peace or Municipal Court, as provided by the Judiciary Act as amended. Therefore, the Court of First Instance correctly granted the motion to quash.
Main Doctrine
Palay, being unhulled rice and a grain in its original state capable of germination, falls within the definition of 'cereal' or 'semilla alimenticia' as contemplated in Article 303 of the Revised Penal Code, which provides for a lower penalty for robbery of such items. Consequently, offenses involving the theft of palay, if the value does not exceed P250.00, fall under the jurisdiction of the Justice of the Peace or Municipal Court, not the Court of First Instance.