### Facts:
1. **Accusation of Vagrancy**: Romulo Intia y Morada, aged 17, was charged with vagrancy by the Naga City Fiscal’s Office on February 10, 1976, under Article 202, paragraph 2 of the Revised Penal Code.
2. **Dismissal by Respondent Judge**: On March 6, 1976, Judge Mericia B. Palma dismissed the case, citing lack of jurisdiction, and suggested refiling in the Juvenile Court.
3. **Different Jurisdictional Views**: The prosecution contended that jurisdiction should remain with the regular courts for individuals aged 16 to under 21, as per Republic Act 6591 and subsequent laws, contrary to Judge Palma’s interpretation.
4. **Petition Filed**: Attorney for the People of the Philippines petitioned the Supreme Court to resolve the jurisdictional conflict.
### Procedural Posture:
– **City Court Ruling**: Judge Palma dismissed the case, advising for it to be refilled in the Juvenile Court.
– **Appeal to the Supreme Court**: Prosecution filed a petition questioning the dismissal and arguing for the Naga City Court’s jurisdiction over Intia’s case.
### Issues:
1. **Whether the issuance of the Child and Youth Welfare Code (P.D. 603) transferred jurisdiction over criminal cases involving accused aged 16 to under 21 from regular courts to Juvenile Courts.**
2. **Whether the definition of a youthful offender in P.D. 603 implicitly modified the jurisdiction established under R.A. 6591.**
3. **Whether a general law could implicitly repeal or modify a special law.**
4. **The applicability of provisions outlined in P.D. 603 concerning the welfare and rehabilitation of youthful offenders.**
### Court’s Decision:
1. **Jurisdiction Not Transferred**: The Supreme Court ruled that the definition of a youthful offender in the Child and Youth Welfare Code did not transfer jurisdiction over criminal cases involving those aged 16 to under 21 from the regular courts to Juvenile Courts.
– **Reasoning**: The Court emphasized that R.A. 6591, a special law, expressly conferred jurisdiction on the Juvenile Courts for accused individuals aged under 16 years at the time of filing the case. P.D. 603, being a general law, could not implicitly transfer jurisdiction.
2. **Express Repeal Required**: The Court held that jurisdiction is conferred by express statutes and there was no express repeal or modification via P.D. 603 affecting the jurisdiction defined by R.A. 6591.
3. **General vs. Special Law**: As a general principle, a special law (R.A. 6591) remains effective against a general law (P.D. 603) unless there is an express repeal or modification.
4. **Provisions of P.D. 603**: Chapter 3 of P.D. 603, orienting on youthful offenders’ welfare, remains applicable irrespective of whether the cases are with Juvenile or regular courts.
### Doctrine:
1. **Jurisdiction of Juvenile Courts**: Special provisions conferred by a specific law (R.A. 6591) cannot be overridden by implications from a general law (P.D. 603). Jurisdiction remains as explicitly defined unless repealed or modified expressly and specifically.
2. **Special vs. General Law**: A general law cannot repeal or modify a special law by mere implication; such changes must be expressly stated.
3. **Holistic Application of Welfare Laws**: Provisions aimed at rehabilitation and welfare (as specified in P.D. 603) apply to youthful offenders independently of which court handles the case.
### Class Notes:
1. **Special Law Takes Precedence Over General Law**: Unless specifically repealed or modified, a special law will prevail over conflicting general laws.
2. **Jurisdiction Based on Explicit Statutes**: Jurisdiction conferred by law is strictly defined in statutes and cannot be assumed to be transferred or modified without express legislative intent.
3. **P.D. 603 Key Provisions for Youthful Offenders**: Articles 190-199 outline comprehensive criteria for dealing with youthful offenders’ trial and rehabilitation regardless of jurisdiction.
– **Article Example**: Article 192 on the suspension of sentence and commitment to proper care emphasizes the rehabilitative focus for offenders under 21 years.
### Historical Background:
This case emerged during the aftermath of the Philippines’ Martial Law era, underscoring the evolving landscape of juvenile justice. R.A. 6591 predated the Child and Youth Welfare Code, indicating legislative development towards focusing on the specific needs and rehabilitation of youthful offenders, a trend further solidified by the application of P.D. 603 aimed at comprehensive care and rehabilitation of youth within legal frameworks.
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