Miguel Ambrose A.
Frias
2022-0267
Statutory Construction
Friday, 7:30-9:30PM
People v Villanueva
G.R. No. L-15014
Date of the Decision: April 29, 1961
Facts:
Victoriano Villanueva was accused of the crime of serious and less serious physical injuries
with damage to propery in the amount of Php 2,636 through reckless imprudence. After
pleading not guilty to he charge before the hearing of the case, a memorandum questioning
the jurisdiction of the justice of the peace court was filed by the private prosecutor on the
ground that the amount of the fine imposable upon the accused is beyond the jurisdiction of
the justice of the peace court. On November 24, 1958, the justice of the peace court
declared itself without jurisdiction to try the case and forwarded it to the Court of First
Instance for further proceedings.
A similar information was filed against the accused in the latter court. Before the accused
could be arraigned, his counsel moved to quash the information on the ground that the
court had no jurisdiction over the complex crime charged. Finding merit in the motion, the
Court of First Instance declared itself without jurisdiction on the ground that the penalty for
the more serious offense of physical injuries through reckless imprudence is only arresto
mayor in its minimum and medium periods, and even applied in its maximum degree (for
the complex crime), it would remain within the jurisdiction of the justice of the peace court.
It then ordered the return of the case to the justice of peace for trial on the merits.
Issue:
Whether or not the First Court of Instance has jurisdiction over the case.
Held:
YES. In Angeles, et al. vs. Jose, 50 O.G. No. 12, 5764, the Court held that: "The above-
quoted provision (Art. 365, par. 3, Revised Penal Code) simply means that if there is only
damage to property the amount fixed therein shall be imposed, but if there are also physical
injuries there should be an additional penalty for the latter. The information cannot be split
into two; one for the physical injuries and another for the damage to property, for both the
injuries and the damage committed were caused by one single act of the defendant and
constitute what may be called a complex crime of physical injuries and damage to property.
It is clear that the fine fixed by law in this case is beyond the jurisdiction of the municipal
court and within that of the court of first instance."
Considering that it is the court of first instance that would undoubtedly have jurisdiction if
the only offense that resulted from appellant's imprudence were the damage to property in
the amount of P2,636.00, it would be absurd to hold that for the graver offense of serious
and less serious physical injuries combined with damage to property through reckless
imprudence, jurisdiction would lie in the justice of the peace court. The presumption is
against absurdity, and it is the duty of the courts to interpret the law in such a way as to
avoid absurd results. Our system of apportionment of criminal jurisdictions among the
various trial courts proceeds on the basic theory that crimes cognizable by the Courts of
First Instance are more serious than those triable in justice of the peace or municipal courts.
Moreover, we cannot discard the possibility that the prosecution may not be able to prove
all the supposed offenses constituting the complex crime charged. Were we to hold that it is
the justice of the peace court that has jurisdiction in this case, if later the prosecution
should fail to prove the physical injuries aspect of the case and establish only the damage to
property in the amount of P2,636.00, the inferior court would find itself without jurisdiction
to impose the fine for the damage to property committed, since such fine cannot be less
than the amount of the damage. Again, it is to avoid this further absurdity that we must
hold that the jurisdiction lies in the court of first instance in this case.
WHEREFORE, the order appealed from is reversed, and the records are remanded to the
court a quo for trial on the merits.
