Salcedo v. Bans
REITERATIONFacts
The Antecedents: Petitioner Florenda Salcedo filed two separate complaints: one for Grave Coercion against Howard Alexander and another for Unjust Vexation against Richard Roynon, before the Municipal Trial Court (MTC) of Olongapo City. The MTC Judge treated these cases under the Rule on Summary Procedure in Special Cases and ordered the private respondents to submit counter-affidavits. Procedural History: Private respondents filed identical Motions to Dismiss, arguing that the MTC lacked jurisdiction because the cases were initiated by complaints filed by the offended party, not by Informations filed by the Fiscal, as allegedly required by Section 9 of the Rule on Summary Procedure. The MTC denied these motions. Subsequently, private respondents filed a Petition for certiorari and Prohibition with Writ of Preliminary Injunction before the Regional Trial Court (RTC), Branch LXXII, Olongapo City. The RTC Judge issued a consolidated Order nullifying the MTC's orders and enjoining further proceedings. The Petition: Petitioner Salcedo filed the present Petition for certiorari, questioning the RTC's interpretation of Section 9 of the Rule on Summary Procedure, specifically whether the filing of an Information is a jurisdictional requirement.
Issue(s)
Whether the requirement in Section 9 of the Rule on Summary Procedure that criminal cases in chartered cities shall be commenced only by Information is a jurisdictional requirement. Whether the RTC erred in declaring the MTC's orders null and void and enjoining further proceedings.
Ruling
The Supreme Court set aside the assailed Order of the respondent RTC Judge dated April 4, 1984. It directed the Municipal Trial Court in Olongapo City to refer the Complaints in question to the City Fiscal of Olongapo City for the filing of the corresponding Informations, if so warranted, and to suspend further hearings in the meantime.
Ratio Decidendi
On the issue of whether the requirement for filing an Information is jurisdictional: The Court held that the requirement in Section 9 of the Rule on Summary Procedure, stating that in Metropolitan Manila and chartered cities, criminal cases covered by the Rule shall be commenced only by Information, is not a jurisdictional requirement but a procedural rule. Jurisdiction is conferred by law, and the Rule on Summary Procedure, by its title, does not determine or affect the jurisdiction of the courts. The rule merely prescribes the specific pleading to be filed to commence a criminal case under its purview. Therefore, the MTC's jurisdiction was not lost simply because the cases were initiated by complaints instead of informations. The Court cited the Solicitor General's opinion that this requirement is merely procedural, indicating the proper manner of initiating a case under the Rule. On the issue of whether the RTC erred in declaring the MTC's orders null and void: The Court found that the respondent Judge erred in sustaining the Motions to Dismiss and declaring the MTC's orders null and void, precisely because the filing of an Information is not a jurisdictional requirement. The proper procedure, according to the Court, should have been to refer the cases to the City Fiscal for the filing of the appropriate Informations, rather than dismissing them outright. This approach aligns with the intent of the Rule on Summary Procedure and the constitutional mandate for judicial supervision. The Court acknowledged that while the Olongapo City Charter grants the Municipal Trial Court the power to conduct preliminary investigations, as a matter of policy under its supervisory powers, it directed the MTC to refer complaints to the City Fiscal for the filing of Informations when cases covered by the Rule are initiated by complaint.
Main Doctrine
The requirement that criminal cases covered by the Rule on Summary Procedure in chartered cities must be commenced by Information is a procedural rule, not a jurisdictional requirement. Failure to comply with this procedural rule does not divest the court of its jurisdiction, but the proper procedure is to refer the complaint to the City Fiscal for the filing of the appropriate Information.