People v. Court of First Instance of Oriental Mindoro
REITERATIONFacts
The Antecedents: On January 10, 1980, Luz A. Marquez filed a complaint for Grave Slander against Matilde Fesalvo with the Municipal Court of Calapan, Oriental Mindoro. Private respondent pleaded not guilty. After trial, the Municipal Court found private respondent guilty of slight oral defamation and sentenced her to pay a fine of P200.00, attorney's fees of P2,000.00, and costs. Procedural History: Private respondent appealed the decision to the Court of First Instance (CFI) of Oriental Mindoro. The CFI took cognizance of the case and required the parties to submit memoranda. On September 23, 1982, the CFI promulgated its decision dated August 31, 1982, reversing the Municipal Court's decision and acquitting private respondent on the ground that the quantum of evidence for grave slander was not met. Petitioner filed a motion for reconsideration assailing the CFI's decision on jurisdictional grounds, which was denied. The Petition: Petitioner filed a petition for certiorari to review and annul the CFI's decision, contending that the CFI lacked appellate jurisdiction over the case.
Issue(s)
Whether the Court of First Instance of Oriental Mindoro had appellate jurisdiction over the criminal case for grave slander decided by the Municipal Court. Whether the appeal filed by the private respondent with the Court of First Instance was valid.
Ruling
The petition is granted. The decision rendered by the respondent Court of First Instance of Oriental Mindoro is set aside for lack of appellate jurisdiction. The appeal taken by private respondent to the then CFI of Oriental Mindoro is considered an appeal to the Court of Appeals (now Intermediate Appellate Court) and the record of the case is ordered remanded to the Intermediate Appellate Court for review on the merits.
Ratio Decidendi
On the issue of appellate jurisdiction: The Supreme Court reiterated the well-settled jurisprudence regarding the jurisdiction of inferior courts and courts of first instance under the Judiciary Act of 1948, as amended. The offense of grave oral defamation carries a maximum penalty of prision correccional in its minimum period, which is imprisonment not exceeding 2 years and 4 months. This penalty falls within the concurrent jurisdiction of the inferior courts and the courts of first instance. Consequently, an appeal from a decision of the Municipal Court in such a case should be made directly to the Court of Appeals, not the Court of First Instance. The Court cited Esperat vs. Avila, Manigla vs. Lantin, People vs. Doriquez, Andico vs. Roan, and Le Hua vs. Reyes to support this established principle. The Court emphasized that the Judiciary Act of 1948, as amended by Republic Acts 2613 and 6031, clearly delineated the appellate routes for cases falling under exclusive and concurrent jurisdictions. Cases under concurrent jurisdiction, when appealed, must go to the Court of Appeals. On the validity of the appeal to the CFI: Since the offense of grave oral defamation falls under the concurrent jurisdiction of the municipal and first instance courts, the appeal from the Municipal Court's decision should have been filed with the Court of Appeals. The appeal having been erroneously filed with the CFI, the proceedings held therein and the decision rendered by the CFI are deemed null and void for want of jurisdiction. The Court invoked Section 31 of the Judiciary Act, as amended, which allows for the transfer of cases erroneously brought to the Supreme Court or Court of Appeals to the proper court. By analogy, the appeal to the CFI was treated as an appeal to the Court of Appeals. The Court also noted that under Batas Pambansa Blg. 129, the zone of concurrent jurisdiction was abolished, and appeals from Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts are now appealable to the Regional Trial Courts. However, BP 129 was not applied retroactively as the Municipal Court had already rendered its decision before its implementation.
Main Doctrine
A decision of a municipal court in a case falling under its concurrent jurisdiction with the Court of First Instance, when appealed, should be elevated to the Court of Appeals, not the Court of First Instance. An appeal erroneously filed with the Court of First Instance is void for lack of jurisdiction.