Rilloraza v. Arciaga
REITERATIONFacts
The Antecedents: Respondent Eulalia Banayat filed a criminal complaint for direct assault upon a person in authority against petitioner Porfirio Rilloraza in the Municipal Court of San Fernando, La Union. The alleged offense occurred in Naguilian, La Union. Procedural History: Petitioner moved to quash the complaint for lack of jurisdiction, which was denied. Three prosecution witnesses testified. Petitioner then filed a petition for certiorari and prohibition with the Court of First Instance of La Union. The Court of First Instance declared the proceedings null and void and ordered the record transmitted to the Municipal Court of Naguilian for preliminary investigation. The Petition: The present appeal questions the order of the Court of First Instance.
Issue(s)
Whether the Municipal Court of San Fernando, La Union, had jurisdiction to try the case for direct assault upon a person in authority. Whether Republic Act No. 3828, enacted after the institution of the criminal action, divested the Municipal Court of its jurisdiction.
Ruling
The Supreme Court reversed and set aside the order of the Court of First Instance, dismissed the petition for certiorari and prohibition, and directed the Municipal Court of San Fernando, La Union, to continue with the case until final determination.
Ratio Decidendi
On whether the Municipal Court of San Fernando, La Union, had jurisdiction to try the case for direct assault upon a person in authority: The Court held that jurisdiction is determined by the law in force at the time the action is instituted. At the time the criminal complaint was filed on June 18, 1963, Republic Act No. 2613 was in effect. This law empowered the Justice of the Peace Court in provincial capitals to hear cases where the penalty did not exceed prision correccional or imprisonment for not more than six years or a fine not exceeding three thousand pesos or both. The charge of direct assault upon a person in authority under Article 148 of the Revised Penal Code carries a penalty of prision correccional in its medium and maximum periods and a fine not exceeding one thousand pesos. Therefore, the Municipal Court of San Fernando, being the capital of La Union, had jurisdiction to try the case. On whether Republic Act No. 3828, enacted after the institution of the criminal action, divested the Municipal Court of its jurisdiction: The Court reiterated the rule that once jurisdiction is acquired, it remains with the court until the case is finally determined. A subsequent statute removing jurisdiction will not operate to oust jurisdiction already attached, unless express prohibitory words are used. The Court cited Iburan vs. Labes and an earlier case from 1913 to support the principle that it is a subversion of judicial power to take a cause from a court having jurisdiction before its final decision is given. The enactment of Republic Act No. 3828 on June 22, 1963, four days after the complaint was filed, did not divest the Municipal Court of San Fernando of its jurisdiction over the case. The Court also dismissed the argument that Republic Act No. 3828 was penal in nature and should be given retroactive effect, stating that the law merely delineates jurisdiction and does not define crimes or provide penalties, thus it cannot have retroactive effect. Uprooting the action and refiling it in another court would not serve public interest, especially when the hearing had already commenced.
Main Doctrine
Jurisdiction of a court of justice to try a criminal case is determined by the law in force at the time the action is instituted. Once jurisdiction is acquired, it remains with the court until the case is finally determined, and a subsequent statute removing jurisdiction will not operate to oust jurisdiction already attached, unless express prohibitory words are used.