People v. Mesias
REITERATIONFacts
The Antecedents: The accused, Arsenio Mesias y Regala, was charged with robbery under Article 303 of the Revised Penal Code for allegedly entering a warehouse by breaking a padlock and stealing seven sacks of rice valued at P42. Procedural History: Before arraignment, the accused filed a motion to dismiss, arguing that the stolen rice, being a cereal, fell under the English text's definition of 'cereal' and thus under a lesser penalty, placing the case within the municipal court's jurisdiction. The trial court sustained the motion and ordered the fiscal to file the information in the municipal court. The Petition: The People of the Philippines, through the Solicitor General, appealed the order of dismissal, contending that 'hulled rice' was not within the meaning of 'semilla alimenticia' as used in the Spanish text of Article 303 of the Revised Penal Code.
Issue(s)
Whether the stolen 'rice' falls under the definition of 'semilla alimenticia' as used in Article 303 of the Revised Penal Code. Whether the case falls within the jurisdiction of the municipal court or the Court of First Instance.
Ruling
The appealed order is reversed. The case is remanded to the court of origin for trial on the merits.
Ratio Decidendi
On the definition of 'semilla alimenticia' and jurisdiction: The Court held that the Spanish text of the Revised Penal Code prevails in cases of doubt. The term 'semilla alimenticia' refers to a seedling or the immediate product of the soil. Hulled rice (arroz) is not a seedling because it is a product obtained from unhulled rice (palay) through labor. Therefore, the stolen hulled rice does not fall under Article 303 of the Revised Penal Code. The accused's contention that 'rice' includes 'palay' and thus 'semilla alimenticia' was rejected. The Court cited dictionary definitions and legal commentary to support its interpretation of 'semilla alimenticia.' The offense, not falling under Article 303, is penalized under the second to the last paragraph of Article 302, which falls under the jurisdiction of the Court of First Instance, not the municipal court. The doubt, if any, should be resolved in favor of the accused, but in this instance, the interpretation of the Spanish text is clear. On the prevailing text in case of doubt: The Court reiterated the principle that in cases of doubt in the interpretation of the Revised Penal Code, the Spanish text should prevail, citing the case of People vs. Samonte. This principle is crucial for ensuring uniformity and correctness in the application of the law, especially when translations might lead to ambiguity. The Court's reliance on the Spanish text underscores its importance in understanding the original intent and scope of the penal provisions.
Main Doctrine
The Spanish text of the Revised Penal Code prevails in cases of doubt. Hulled rice (arroz) is not considered 'semilla alimenticia' (seedling) as it is a product obtained from unhulled rice (palay) through labor, not an immediate product of the soil.