Morales v. Court of Appeals
ABANDONMENTFacts
1. The Antecedents: Petitioner Ernesto Morales y Dela Cruz was charged with selling 0.4587 grams of methamphetamine hydrochloride (shabu), a violation of Section 15 in relation to Section 20 of Republic Act No. 6425, as amended by Republic Act No. 7659. The information was filed before the Regional Trial Court (RTC) of Pasay City. 2. Procedural History: Upon arraignment, Morales pleaded not guilty and subsequently filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction due to the small quantity of the drug involved, which, under Republic Act No. 7659 and Republic Act No. 7691, should place the case under the jurisdiction of the Metropolitan Trial Court. The RTC denied this motion, citing Section 39 of Republic Act No. 6425, which grants the RTC concurrent original jurisdiction over all cases involving violations of the Dangerous Drugs Act. Morales then filed a petition for certiorari with the Court of Appeals, which dismissed the petition for lack of jurisdiction. Morales then elevated the matter to the Supreme Court. 3. The Petition: The petitioner filed a petition for review under Rule 45 of the Rules of Court, raising two main issues: first, whether the Court of Appeals had jurisdiction to entertain a petition for certiorari concerning the jurisdiction of the RTC, and second, whether the RTC had jurisdiction to try the alleged violation of Republic Act No. 6425 involving only 0.4587 grams of shabu. The petitioner argued that the Court of Appeals had concurrent original jurisdiction with the Supreme Court over such petitions and that the RTC lacked jurisdiction due to the quantity of the drug, which should fall under the exclusive jurisdiction of lower courts as per Republic Act No. 7691.
Issue(s)
Whether the Court of Appeals has jurisdiction to entertain a petition for certiorari under Rule 65 of the Rules of Court where the issue is the jurisdiction of the respondent RTC Judge to try the alleged violation of R.A. No. 6425. Whether the respondent RTC Judge/Court has jurisdiction to try alleged violation of Section 15, in relation to Section 20, Art. III of R.A. No. 6425, as amended, involving only 0.4587 grams of shabu.
Ruling
The petition is GRANTED, but only insofar as the issue of jurisdiction of respondent Court of Appeals in CA-G.R. SP No. 40670 is concerned. The Resolutions of 8 August and 13 September 1996 of the Court of Appeals are SET ASIDE, while the challenged orders in Criminal Case No. 96-8443 of the Regional Trial Court of Pasay City, Branch 116, are AFFIRMED. The trial court is hereby DIRECTED to proceed with the trial of Criminal Case No. 96-8443 with all reasonable dispatch.
Ratio Decidendi
On the jurisdiction of the Court of Appeals: The Court held that the Court of Appeals erred in dismissing the petition for certiorari for lack of jurisdiction. Under Section 9(1) of B.P. Blg. 129, the Court of Appeals has concurrent original jurisdiction with the Supreme Court to issue writs of certiorari. The provisions cited by the CA (Section 5(2)(c) of Article VIII of the Constitution and Section 17 of the Judiciary Act of 1948) pertain to the Supreme Court's appellate jurisdiction, not its original jurisdiction over special civil actions for certiorari. Therefore, the CA should have resolved the petition on its merits. However, considering the importance of the issue and to avoid further delay, the Supreme Court took direct cognizance of the case. On the jurisdiction of the Regional Trial Court: The Court affirmed the RTC's jurisdiction. While R.A. No. 7691 amended Section 32 of B.P. Blg. 129 to grant MTCs exclusive original jurisdiction over offenses punishable with imprisonment not exceeding six years, this amendment contains an exception for cases falling within the exclusive original jurisdiction of Regional Trial Courts. Section 39 of R.A. No. 6425, as amended by P.D. No. 44, specifically vests concurrent original jurisdiction in Courts of First Instance (now RTCs) over all cases involving violations of the Dangerous Drugs Act. This special law prevails over the general law (R.A. No. 7691). Therefore, even though the imposable penalty for 0.4587 grams of shabu would not exceed prision correccional (six years), the RTC retains jurisdiction. The Court clarified that the abolition of Courts of First Instance did not abolish their exclusive original jurisdiction in drug cases, as RTCs merely replaced them. The Court also abandoned its previous resolution in Gulhoran v. Escaño which held that Section 39 of R.A. No. 6425 was repealed by R.A. No. 7691.
Main Doctrine
Regional Trial Courts retain exclusive original jurisdiction over violations of R.A. No. 6425, as amended, even if the imposable penalty does not exceed six years, due to the specific provisions of Section 39 of R.A. No. 6425, as amended by P.D. No. 44, which are considered special laws that prevail over the general provisions of R.A. No. 7691 amending B.P. Blg. 129.