People v. Eduarte
REITERATIONFacts
1. The Antecedents: The case involves a criminal information for concubinage filed against Elvino Aggabao and Villa Suratos. The alleged crime occurred in September 1983. The complaint was initiated by Alma T. Aggabao, who was represented by a private prosecutor during the proceedings. 2. Procedural History: The information was filed with the Regional Trial Court (RTC) of Cabagan, Isabela, Branch 22, on July 25, 1986. After the private respondents pleaded not guilty, they filed a motion to dismiss, arguing that the RTC lacked jurisdiction because the penalty for concubinage, specifically destierro for the concubine, falls within the purview of lower courts. The RTC granted this motion, dismissing the case. The People of the Philippines, through a private prosecutor and an assistant provincial prosecutor, filed a petition with the Supreme Court assailing this dismissal. The Supreme Court initially denied the petition due to late payment of fees and lack of merit, but later reconsidered upon motion by the Solicitor General and the private prosecutor. 3. The Petition: The petition, initially filed by the private prosecutor and assistant provincial prosecutor, assails the RTC's order dismissing the concubinage charge for lack of jurisdiction. The core argument presented by the petitioner is that the RTC erred in finding that it lacked jurisdiction, contending that the penalty of destierro for the concubine, which has a duration of six months and one day to six years, falls outside the exclusive jurisdiction of inferior courts. The petition also raised the issue of estoppel, arguing that the private respondents should not be allowed to question jurisdiction after participating in the proceedings for an extended period. The Supreme Court, however, ultimately denied the petition, holding that the RTC correctly dismissed the case as concubinage falls within the exclusive original jurisdiction of inferior courts.
Issue(s)
Whether the private respondents are estopped from raising the issue of jurisdiction after participating in the trial. Whether the Regional Trial Court has original jurisdiction over the crime of concubinage.
Ruling
The petition is DENIED for lack of merit. The Court held that the RTC committed no reversible error in dismissing the criminal information for concubinage on the ground of lack of jurisdiction. The offended wife is not precluded from initiating the filing of another criminal information against private respondents before the proper court, as the dismissal on jurisdictional grounds is not a bar to another prosecution and the crime has not prescribed.
Ratio Decidendi
On the issue of estoppel from raising jurisdiction: The Court held that the contention that private respondents are estopped from raising the issue of jurisdiction is without merit. It is a settled rule in the Philippine legal system that the question of jurisdiction may be raised at any stage of the proceedings. While there are exceptions, such as in Tijam v. Sibonghanoy, where jurisdiction was raised for the first time on appeal after almost fifteen years, the present case is distinguishable. In this case, the jurisdictional challenge was made pending trial and before any judgment on the merits was rendered. The pivotal element of laches, present in Tijam, is absent here, as the accused promptly filed a motion to dismiss upon discovering the alleged defect. Therefore, the general rule that jurisdiction can be questioned at any stage applies, and private respondents are not estopped. On the jurisdiction of the Regional Trial Court over concubinage: The Court ruled that the Regional Trial Court (RTC) does not have original jurisdiction over the crime of concubinage. The crime of concubinage is penalized under Article 334 of the Revised Penal Code (RPC). The penalty for the husband is prision correccional in its minimum and medium periods (6 months and 1 day to 4 years and 2 months), which is within the exclusive original jurisdiction of the inferior courts as defined by Section 32 of B.P. Blg. 129. The penalty for the concubine is destierro. The Court reiterated the doctrine established in Uy Chin Hua v. Dinglasan and People v. Santos that a crime punishable with destierro is within the jurisdiction of the inferior courts. This is because destierro, which means banishment, is considered a lighter penalty than arresto mayor (imprisonment), despite potential duration differences, based on the degree of deprivation of liberty. The Court clarified that even under the Judiciary Reorganization Act of 1980 (B.P. Blg. 129), which grants inferior courts exclusive original jurisdiction over offenses punishable with imprisonment not exceeding four years and two months, the intention was not to overturn the established doctrine regarding destierro. The allocation of jurisdiction is based on the gravity of the offense and the imposable penalty, and since destierro is lighter than imprisonment, it remains within the purview of inferior courts. Furthermore, considering that the offended party must include both the husband and the concubine in the prosecution, it is in the interest of justice for both to be tried before the inferior courts, avoiding a split jurisdiction scenario.
Main Doctrine
The crime of concubinage falls within the exclusive original jurisdiction of the inferior courts, not the Regional Trial Courts, as the penalty of destierro is considered lighter than arresto mayor and thus cognizable by lower courts. Furthermore, the issue of jurisdiction may be raised at any stage of the proceedings unless barred by laches.