People v. Veray
REITERATIONFacts
1. The Antecedents: The appellant was convicted in the municipal court of Manila for the theft of a pin valued at P200, receiving a sentence of three months of arresto mayor. Upon retrial in the Court of First Instance following an appeal, the appellant was again convicted of the same charge and sentenced to two months and one day of arresto mayor. 2. Procedural History: The case originated in the municipal court of Manila where the appellant was convicted of theft. An appeal was then lodged with the Court of First Instance, which conducted a retrial and also convicted the appellant. The present appeal to the Supreme Court stems from this conviction in the Court of First Instance. 3. The Petition: The appeal to the Supreme Court centers on the jurisdiction of the municipal court of Manila over the crime of larceny, specifically concerning the value of the property stolen, and the subsequent right of appeal from the Court of First Instance to the Supreme Court in such cases. The appellant contends that the statute granting concurrent jurisdiction to municipal courts over certain offenses, including larceny where the value does not exceed one hundred dollars, does not implicitly divest the Supreme Court of its appellate jurisdiction over judgments from the Court of First Instance in these matters.
Issue(s)
Whether the municipal court of Manila had concurrent jurisdiction with the Court of First Instance over the crime of larceny where the value of the property stolen did not exceed one hundred dollars, as provided by Act No. 267. Whether the right of appeal to the Supreme Court from judgments of conviction in the Court of First Instance, in cases where the municipal court exercised its concurrent jurisdiction under Act No. 267, was cut off by implication.
Ruling
The Supreme Court ruled that the right of appeal to the Supreme Court from judgments of conviction in the Court of First Instance, in cases where the municipal court exercised its concurrent jurisdiction under Act No. 267, is not cut off by implication. The Court found that the trial judge's belief that no appeal would lie from his judgment led to the omission of stenographic notes, necessitating a new trial.
Ratio Decidendi
On the jurisdiction of the municipal court: The Court affirmed that the municipal court of Manila had concurrent jurisdiction with the Courts of First Instance over larceny cases where the value of the property stolen did not exceed one hundred dollars, as explicitly provided in the last paragraph of section 10 of Act No. 267. This grant of jurisdiction was within the plenary power of the Philippine Commission at the time of enactment and was further confirmed by the Act of Congress of July 1, 1902. On the right of appeal to the Supreme Court: The Court held that the phrase "as in other cases" in Act No. 267, referring to appeals to the Court of First Instance, pertained only to the procedural transfer and hearing of the case in the appellate court. It did not intend to cut off the right of appeal to the Supreme Court, which had been secured to convicts in similar cases under section 43 of General Orders No. 58. The Court emphasized that statutes are not construed to oust or restrict the jurisdiction of superior courts, or to vest new jurisdiction, unless there are express words or a necessary implication to that effect. The contention that the right of appeal was cut off rested on doubtful inference and a strained construction of the statute, which could not be maintained. The potential for severe penalties in these cases further supported the presumption that the right to a review by the Supreme Court was not intended to be denied without explicit language.
Main Doctrine
The right of appeal to the Supreme Court from judgments of conviction in the Court of First Instance, in cases where the municipal court exercised its concurrent jurisdiction under Act No. 267, is not cut off by implication, absent express words or necessary implication in the statute.