People v. Fernando
REITERATIONFacts
The Antecedents: Marina David filed a charge for grave threats against Felix Fernando. Procedural History: The Court of First Instance of Nueva Ecija dismissed the charge for grave threats on the ground of lack of jurisdiction, opining that the penalty for grave threats (arresto mayor and a fine not exceeding P500.00) did not reach the minimum limit of the Court of First Instance's jurisdiction based on the amendment to Section 87(c) of the Judiciary Act. The Petition: The Government appealed the dismissal order, contending that the crime charged falls within the concurrent jurisdiction of inferior courts and courts of first instance, citing Section 44(f) of the Judiciary Act.
Issue(s)
Whether the Court of First Instance has original jurisdiction over a case for grave threats punishable by arresto mayor and a fine not exceeding P500.00, notwithstanding the expanded jurisdiction of municipal courts.
Ruling
The order of dismissal is hereby set aside, and the case is remanded to the lower court for trial on the merits. Order reversed.
Ratio Decidendi
On Issue 1: The Court ruled that the Court of First Instance (CFI) and municipal courts have concurrent jurisdiction over the offense. Applying the precedent in Esperat v. Avila (G.R. No. L-25922), the Court explained that Section 44(f) of the Judiciary Act grants the CFI original jurisdiction in cases where the penalty is imprisonment for more than six months or a fine of more than P200.00. While Section 87(c) was amended to broaden the jurisdiction of municipal and city courts to include offenses punishable by up to three years or a fine of P3,000.00, the jurisdiction of the CFI remained unaltered. This creates a 'zone' where jurisdictions overlap, specifically where the penalty is more than six months but not exceeding three years, or the fine is more than P200.00 but not exceeding P3,000.00. Because the fine for grave threats can reach P500.00 (exceeding the P200.00 threshold), the CFI possesses original jurisdiction concurrent with the municipal court. Consequently, the court that first takes cognizance of the case acquires jurisdiction to the exclusion of the other.
Main Doctrine
The crime of grave threats, punishable by arresto mayor and a fine not exceeding P500.00, falls under the concurrent jurisdiction of the municipal court and the Court of First Instance. Whichever court first takes cognizance of the case acquires jurisdiction thereof exclusive of the other.