People v. Pablo
REITERATIONFacts
The Antecedents: The Acting Chief of Police of Bolinao, Pangasinan filed a complaint with the Municipal Court against Florendo Caracas, Jr. for serious physical injuries, alleging that the accused unlawfully attacked Mariano Caasi y Romero with a stone, causing him to lose seven (7) teeth and deform his mouth. The offense was alleged to have been committed during nighttime. Procedural History: The Municipal Court forwarded the case to the Court of First Instance (CFI) of Pangasinan after the accused waived preliminary investigation. However, the Provincial Fiscal filed a motion to remand the case to the Municipal Court, arguing that the offense fell under the concurrent jurisdiction of both courts and that the Municipal Court, having acquired jurisdiction first, should try the case on the merits. The CFI Judge denied the motion, stating the case did not fall within concurrent jurisdiction and later denied the motion for reconsideration. The Petition: The People of the Philippines, through the Provincial Fiscal, filed a petition for certiorari, prohibition, and mandamus, seeking to nullify the CFI's orders denying the motion to remand and to compel the CFI to remand the case to the Municipal Court for trial on the merits.
Issue(s)
Whether the Court of First Instance erred in denying the motion to remand the case to the Municipal Court for trial on the merits, considering the jurisdiction and necessity of preliminary investigation. Whether the Municipal Court acquired jurisdiction over the case to the exclusion of the Court of First Instance.
Ruling
The petition is granted. The orders of the respondent court dated July 17, 1973, and July 20, 1973, are set aside, and the respondent Judge is ordered to remand the case to the Municipal Court of Bolinao for trial on the merits.
Ratio Decidendi
On the issue of jurisdiction and the necessity of preliminary investigation: The Court held that offenses falling within the concurrent jurisdiction of the municipal court and the Court of First Instance, such as serious physical injuries where the intent to kill is not charged or evident, are covered by Section 87(c) of the Judiciary Act of 1948. In such cases, the accused is not entitled to a preliminary investigation. The Court reiterated its ruling in People of the Philippines vs. Abejuela and People of the Philippines vs. Endan, which stated that the accused in an offense falling within concurrent jurisdiction is not entitled to a preliminary investigation. The Court explained that preliminary investigations in such cases lead to loss of time and protracted litigation, which are eliminated by the assurance of a speedy and expeditious trial upon arraignment. The first stage of preliminary investigation, which involves the examination of complainants and witnesses, is generally sufficient to establish reasonable grounds to charge the accused. Therefore, the Municipal Court of Bolinao should have tried the case on the merits instead of conducting a preliminary investigation and forwarding it to the CFI. The filing of the case with the Municipal Court vested it with jurisdiction to the exclusion of the CFI. The Fiscal was correct in contending that the Municipal Judge erred in forwarding the records to the CFI, and the respondent Judge erred in refusing to remand the case.
Main Doctrine
In offenses falling within the concurrent jurisdiction of inferior courts and Courts of First Instance, the accused is not entitled to a preliminary investigation, and the municipal court, upon filing of the complaint, acquires jurisdiction to the exclusion of the Court of First Instance.