THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLANT, VS. CONCHITA COOK AND S/SGT. DONALD COOK, DEFENDANTS-APPELLEES.

People versus Cook

The Case

This is the People of the Philippines against Conchita Cook and Sergeant Donald Cook, a criminal prosecution for estafa involving the sum of 5,100 pesos, commenced in the City Court of Angeles City in Pampanga. The defendants moved to quash the information on the ground that the court had no jurisdiction over the offense charged, and the city court agreed and dismissed the case. The case matters because it fixes the boundary between the exclusive jurisdiction of municipal and city courts over small estafa and their concurrent jurisdiction with the Court of First Instance over estafa of larger amounts, a distinction every examinee in remedial law and criminal procedure must be able to draw from the Judiciary Act as amended.

Procedural History

The City Fiscal of Angeles City prosecuted the two accused for estafa before the City Court of Angeles City. The accused filed a motion to quash on the sole ground that the court lacked jurisdiction over the offense charged. After hearing the parties, the city court dismissed the case precisely on that ground. The State, through the People of the Philippines, appealed the order of dismissal to the Supreme Court, which resolved the appeal on the question of jurisdiction.

Facts

The City Fiscal of Angeles City charged Donald Cook and Conchita Cook with estafa in the amount of 5,100 pesos. Instead of entering a plea, the accused challenged the proceedings by a motion to quash, arguing that the City Court of Angeles City had no jurisdiction over the offense charged.

The city court heard the parties on the motion and sustained the accused. It dismissed the case on the ground that jurisdiction lay elsewhere.

The People brought the dismissal up on appeal. The Supreme Court was thus called upon to construe the jurisdictional provisions of the Judiciary Act of 1948 as amended by Republic Act 3823, and to determine whether the city court could properly take cognizance of an estafa charge involving 5,100 pesos.

Issues

• Whether or not the City Court of Angeles City has jurisdiction over the estafa charge involving the sum of 5,100 pesos.
• Whether or not the grant of exclusive jurisdiction to municipal and city courts over estafa not exceeding 200 pesos conflicts with their grant of jurisdiction concurrent with the Court of First Instance where the penalty does not exceed prision correccional or a fine of 6,000 pesos.

Applicable Provisions

Paragraph b of Section 87 of the Judiciary Act of 1948, as amended by Republic Act 3823, provides:

Justices of the peace (municipal judges) and judges of municipal courts of chartered cities shall have original and exclusive jurisdiction over all cases of larceny, embezzlement and estafa where the amount of money or property stolen, embezzled, or otherwise involved does not exceed the sum or value of two hundred pesos.

This provision confines the city court's exclusive competence to estafa involving 200 pesos or less, which the 5,100 peso charge exceeds.

Paragraph c of the same Section 87, as amended, provides:

Justices of the peace in the capitals of provinces and subprovinces and judges of municipal courts shall have like jurisdiction as the Court of First Instance to try parties charged with an offense committed within their respective jurisdiction in which the penalty provided by law does not exceed prision correccional or imprisonment for not more than six years or a fine not exceeding six thousand pesos, or both.

This provision supplies the concurrent jurisdiction that sustains the city court's competence over the charge, because the penalty for the offense does not exceed the stated limits.

Article 315, paragraph 3 of the Revised Penal Code, as discussed in the decision, provides a penalty of arresto mayor in its maximum period to prision correccional in its minimum period, which falls within the ceiling fixed by paragraph c.

Ruling

On the first issue, the Court held that the City Court of Angeles City has jurisdiction over the estafa charge. The Court found no conflict between paragraphs b and c of Section 87. As far as estafa is concerned, where the sum of money or value of the property involved does not exceed 200 pesos, municipal and city courts have original and exclusive jurisdiction; but the same courts have original, concurrent jurisdiction with the Court of First Instance over the same cases and others, provided the penalty provided by law does not exceed prision correccional, imprisonment for not more than six years, or a fine not exceeding 6,000 pesos, or both.

On the second issue, the Court held that the two provisions do not conflict. They operate on different planes: one fixes an exclusive competence defined by the amount involved, the other a concurrent competence defined by the penalty prescribed by law. Since the penalty for the estafa charged is arresto mayor in its maximum period to prision correccional in its minimum period, the city court's concurrent jurisdiction was triggered. The dismissal on the ground of lack of jurisdiction was therefore erroneous.

Doctrine

Municipal and city courts have exclusive jurisdiction over estafa where the amount involved does not exceed 200 pesos, and concurrent jurisdiction with the Court of First Instance where the penalty prescribed by law does not exceed prision correccional, imprisonment of not more than six years, or a fine of not more than 6,000 pesos, or both. The two grants do not conflict; the first is measured by the amount involved, the second by the penalty provided by law. Jurisdiction over a criminal case is determined by the penalty prescribed by law for the offense charged, not by the amount alone.

Disposition

The Supreme Court set aside the order of dismissal and remanded the case to the City Court of Angeles City for further proceedings in accordance with law, thus sustaining the People's appeal.

Remember This

The line to memorize is that 200 pesos or less of estafa is exclusive to the municipal or city court, while a penalty within prision correccional gives concurrent jurisdiction with the Court of First Instance. Examiners use this case to test whether you can distinguish jurisdiction measured by the amount involved from jurisdiction measured by the penalty prescribed by law.