People v. Daco
REITERATIONFacts
The Antecedents: A complaint for assault upon an agent of a person in authority was filed against Isidro, Eustaquio, Teodorico, Isaias (all surnamed Daco) and Mario Edonga. The complaint alleged that the accused, confederating, willfully, unlawfully, and feloniously attacked Porfirio Feloteo, a policeman, while in the performance of his official duty, causing him less serious physical injuries. Procedural History: During the preliminary investigation, the Justice of the Peace Court rendered a decision elevating the case against Isidro Daco to the Court of First Instance, but convicting the other four accused (Eustaquio, Teodorico, Isaias, and Mario Edonga) for slight physical injuries and sentencing them to 10 days imprisonment. Subsequently, the provincial fiscal filed an information with the Court of First Instance charging all five accused with assault upon an agent of a person in authority, with physical injuries. The defendants, except Isidro Daco, moved to quash the information on the ground of double jeopardy, asserting that the crime charged included the crime of slight physical injuries for which they had already been convicted and served sentence. The Petition: The Court of First Instance sustained the motion to quash and dismissed the case. The People of the Philippines appealed this dismissal.
Issue(s)
Whether the decision of the Justice of the Peace Court of Busuanga is valid or a nullity. Whether the plea of double jeopardy should be sustained.
Ruling
The order of dismissal appealed from is set aside and the case is remanded to the lower court for further proceedings in accordance with law. Costs de oficio.
Ratio Decidendi
On the validity of the Justice of the Peace Court's decision: The Supreme Court held that Justice of the Peace Courts have no jurisdiction to entertain a case of assault against a person in authority or assault upon an agent of a person in authority, except for the purpose of conducting a preliminary investigation. The records indicated that the Justice of the Peace Court of Busuanga heard the case only to conduct the corresponding preliminary investigation. Therefore, the conviction of Eustaquio, Teodorico, Isaias, all surnamed Daco, and Mario Edonga by the Justice of the Peace Court of Busuanga was a nullity. On the plea of double jeopardy: The Court ruled that for double jeopardy to be sustained, one of its essential elements is a judgment or final order rendered or issued by a competent court. Since the conviction by the Justice of the Peace Court was a nullity due to lack of jurisdiction, it was not a judgment rendered by a competent court. Consequently, the plea of double jeopardy could not be sustained.
Main Doctrine
A conviction rendered by a Justice of the Peace Court for assault upon an agent of a person in authority, when such court only has jurisdiction to conduct a preliminary investigation for such offense, is a nullity. Consequently, a plea of double jeopardy based on such a void conviction cannot be sustained.