People v. Jimenez
REITERATIONFacts
The Antecedents: The underlying dispute concerns a charge of lesiones graves (serious physical injuries) by reckless imprudence against Gregorio Jimenez. The information alleges that Jimenez, while operating electric car No. 150 on November 20, 1918, in Manila, drove carelessly and at excessive speed. This negligence resulted in the car striking and severely injuring a boy named Aurelio Ibañes, causing him to lose his left arm and suffer injuries that would require over thirty days of medical attention and permanently incapacitate him for manual labor. Procedural History: Gregorio Jimenez was tried and convicted in the Court of First Instance of Manila for the crime of lesiones graves by reckless imprudence. He was sentenced to four months of arresto mayor and payment of costs. Following this conviction, Jimenez appealed the decision. The Petition: The Attorney-General, upon reviewing the appellant's brief, filed a motion to dismiss the cause. The basis for this motion was the assertion that the Court of First Instance lacked jurisdiction over the case due to its subject matter. The Attorney-General argued that the penalty prescribed by law for the acts charged, even if committed with malice, would not exceed four months of arresto mayor, placing the case outside the original jurisdiction of the Court of First Instance as defined by section 56, paragraph 6, of Act No. 136. The Supreme Court, in considering the motion, noted that jurisdiction cannot be conferred by waiver, even if the accused did not object to the lower court's jurisdiction.
Issue(s)
Whether the Court of First Instance of Manila had original jurisdiction over the crime of lesiones graves by reckless imprudence, as charged in the information. Whether the accused can confer jurisdiction upon the court by waiver or failure to object.
Ruling
The Supreme Court dismissed the case without special pronouncement as to costs, granting the Attorney-General the right to institute the action in a competent court.
Ratio Decidendi
On whether the Court of First Instance of Manila had original jurisdiction over the crime of lesiones graves by reckless imprudence, as charged in the information: The Court held that the jurisdiction of a court in criminal cases is determined by the facts set out in the complaint. In this case, the information alleged lesiones graves by reckless imprudence. If malice were present, the crime would be lesiones graves, punishable with a correctional penalty. However, with reckless imprudence, the acts fall under Article 568, paragraph 1, case 2 of the Penal Code, which imposes a penalty of arresto mayor in its minimum and medium degrees. The maximum penalty imposable under this provision does not exceed four months of arresto mayor. According to Section 56, paragraph 6, of Act No. 136, the Court of First Instance does not have original jurisdiction over cases where the penalty does not exceed four months of arresto mayor. Therefore, the Court of First Instance lacked jurisdiction. On whether the accused can confer jurisdiction upon the court by waiver or failure to object: The Court reiterated the principle that jurisdiction is conferred by law and cannot be acquired by the consent, express waiver, or any other act of the accused. Even though the accused did not object to the jurisdiction of the court, his silence produces no effect because jurisdiction had not been conferred by law. The ruling in United States v. De la Santa and United States v. Jayme were cited to support this principle.
Main Doctrine
The Court of First Instance lacks original jurisdiction over criminal cases where the maximum imposable penalty does not exceed four months of arresto mayor, as such cases fall under the exclusive jurisdiction of inferior courts.