People v. Lipao
REITERATIONFacts
The Antecedents: Private respondents Rico and Rickson Lipao were indicted for violation of Section 68 of Presidential Decree No. 705, as amended by Executive Order No. 277, for allegedly possessing eight (8) pieces of round timbers and 160 bundles of firewood without legal documents and licenses, and loading them onto a pumpboat. The offense is punishable under Articles 309 and 310 of the Revised Penal Code. Procedural History: The Regional Trial Court (RTC), Branch 32, Surigao City, found the private respondents guilty beyond reasonable doubt and sentenced them to an indeterminate penalty. Subsequently, Republic Act No. 7691, which expanded the jurisdiction of Metropolitan, Municipal Trial Courts, and Municipal Circuit Trial Courts, took effect. The private respondents appealed to the Court of Appeals (CA), arguing illegal search and seizure and lack of proof of their lack of license. The CA, motu proprio, dismissed the case on the ground of lack of jurisdiction of the RTC, citing RA 7691. The Petition: The People of the Philippines filed a Petition for Certiorari under Rule 65, assailing the CA's dismissal of the case for lack of jurisdiction, arguing that the RTC retained jurisdiction despite the passage of RA 7691.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in dismissing the criminal case on the ground of lack of jurisdiction of the Regional Trial Court due to the enactment of Republic Act No. 7691. Whether the Regional Trial Court retained jurisdiction over the criminal case despite the passage of Republic Act No. 7691.
Ruling
The petition is GRANTED. The assailed June 13, 2002 CA Decision in CA-G.R. CR No. 17275 is REVERSED and SET ASIDE. The CA is directed to resolve the appeal of private respondents on the merits and with dispatch.
Ratio Decidendi
On the issue of whether the Court of Appeals committed grave abuse of discretion in dismissing the criminal case on the ground of lack of jurisdiction of the Regional Trial Court due to the enactment of Republic Act No. 7691: The Supreme Court held that the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction. The CA's ruling that the RTC was divested of jurisdiction by reason of RA 7691 was arbitrary and patently erroneous. The Court emphasized that RA 7691's retroactive provisions apply only to civil cases that have not yet reached the pre-trial stage and do not have retroactive application to criminal cases pending or decided by the RTC prior to its effectivity. Therefore, the CA's motu proprio dismissal based on a misapplication of the law constituted grave abuse of discretion. On the issue of whether the Regional Trial Court retained jurisdiction over the criminal case despite the passage of Republic Act No. 7691: The Supreme Court ruled in the negative, affirming that the RTC retained jurisdiction. The Court reiterated the general rule that the jurisdiction of a court to try a criminal action is determined by the law in force at the time of the institution of the action. It further stated that once a court has obtained and is exercising jurisdiction, its jurisdiction to proceed to final determination is not affected by new legislation unless the statute provides for retroactivity. The Court noted that RA 7691 does not expressly or implicitly provide for retroactive application to criminal cases pending before the RTCs prior to its effectivity. Therefore, the RTC's jurisdiction, which attached upon the filing of the information, could not be ousted by the subsequent passage of RA 7691. The Court also found that the CA erred in using values adduced during the hearing to determine jurisdiction, as jurisdiction is determined by the law in force at the commencement of the action and by the allegations in the Information.
Main Doctrine
The jurisdiction of a court to try a criminal action is determined by the law in force at the time of the institution of the action. Where a court has already obtained and is exercising jurisdiction over a controversy, its jurisdiction to proceed to the final determination of the cause is not affected by new legislation placing jurisdiction over such proceedings in another tribunal, unless the statute expressly provides for retroactivity. RA 7691's retroactive provisions apply only to civil cases that have not yet reached the pre-trial stage and do not have retroactive application to criminal cases pending or decided by the Regional Trial Courts prior to its effectivity.