Arcaya v. Teleron
REITERATIONFacts
The Antecedents: On March 1, 1971, a jeep owned by the Philippine National Bank (PNB), allegedly driven by Emmanuel Ceballos, collided with a Volkswagen Combi owned by Doctor Domiciano Nazareno, causing injuries to passengers and damage to property. Reno Arcaya, the regular driver of the jeep and a PNB employee, allegedly allowed Ceballos, also a PNB employee, to drive. Procedural History: The chief of police of Tubigon, Bohol, filed a complaint against Ceballos and Arcaya for "double less serious physical injuries, slight physical injuries and damage to property thru reckless imprudence" (Criminal Case No. 1397). The offended parties were Dr. Remedios N. Relampagos and Paz F. Nazareno (less serious physical injuries), Mary Carlyn Relampagos (slight physical injuries), and Dr. Nazareno (damage to property). Arcaya and Ceballos moved to quash the complaint, arguing that the three offenses could not be joined. In response, the chief of police filed two amended complaints: one for less serious physical injuries and damage to property through reckless imprudence (original docket No. 1397), and another for slight physical injuries through reckless imprudence (docketed as No. 1397-A). Arcaya and Ceballos pressed their motion to quash, adding the ground that the crime of slight physical injuries had prescribed. The municipal court denied the motion. They then filed actions for certiorari and prohibition in the Court of First Instance (CFI) of Bohol to set aside the denial, which the CFI dismissed on April 12, 1973. The Petition: Arcaya and Ceballos belatedly filed the instant actions for certiorari, prohibition, and mandamus in the Supreme Court to review the CFI's resolution. They contended that the municipal court lacked jurisdiction because the offenses were improperly joined and that the slight physical injuries charge had prescribed. They argued that both the municipal court and the CFI acted in excess of jurisdiction and with grave abuse of discretion.
Issue(s)
Whether the filing of the complaint in Criminal Case No. 1397 conferred jurisdiction on the municipal court over the three offenses charged, considering the alleged improper joinder. Whether the municipal court had jurisdiction over the crime of slight physical injuries through reckless imprudence, given the claim that it had already prescribed.
Ruling
The petition is dismissed. The Supreme Court held that the municipal court did not act in excess of jurisdiction and did not commit a grave abuse of discretion in denying the motion to quash. Consequently, the actions for certiorari, prohibition, and mandamus must also fail.
Ratio Decidendi
On the issue of jurisdiction and joinder of offenses: The petitioners' premise that a complaint "confers" jurisdiction is incorrect; jurisdiction is conferred by law. The municipal court of Tubigon possessed exclusive original jurisdiction to try the offense of lesiones leves (slight physical injuries) through reckless imprudence and to conduct a preliminary investigation for the complex crime of lesiones menos graves (less serious physical injuries) and damage to property, both committed through reckless imprudence, as provided by Section 87 of the Judiciary Law. The subsequent amendment separating the offenses did not divest the court of jurisdiction, as the original complaint, despite the joinder issue, was filed within the period for the offenses charged. The Court reiterated that if a court has jurisdiction over the subject matter and the person, its rulings on all questions involved are within its jurisdiction and, however erroneous, must be corrected by appeal, not certiorari. On the issue of prescription: The issue of prescription is not a jurisdictional issue but one to be decided by the court having jurisdiction over the offense. The Court found that the light felony of slight physical injuries had not prescribed. The offense was committed on March 1, 1971, and the original complaint was filed on April 27, 1971, fifty-seven days after commission. Light felonies prescribe in sixty days under Article 90 of the Revised Penal Code. Even if the offense was later separated into a new case (Criminal Case No. 1397-A) on July 9, 1971, after the sixty-day period had passed, the commencement of the criminal action on April 27, 1971, interrupted the prescriptive period. The Court emphasized that when a complaint is amended, the plea of prescription relates back to the time of the filing of the original complaint, citing Pangasinan Transportation Co. vs. Philippine Farming Co., Ltd. The Court also noted that the separation of the charges was a consequence of the petitioners' own motion to quash, possibly guided by jurisprudence suggesting separate informations for distinct offenses arising from the same incident.
Main Doctrine
Certiorari and prohibition do not lie to correct errors of judgment or procedural errors, but only errors of jurisdiction or grave abuse of discretion amounting to lack of jurisdiction. The denial of a motion to quash, even if erroneous, is generally not reviewable by certiorari unless it involves a jurisdictional error.