PEOPLE OF THE PHILIPPINES, PLAINTIFF AND APPELLANT, VS. VICTORIANO VILLANUEVA, DEFENDANT AND APPELLEE.

In Criminal Case No. 2801 of the Justice of the Peace Court of Batangas,
Batangas, Victoriano Villanueva was accused of the crime of serious and less
serious physical injuries with damage to property in the amount of P2,636.00
through reckless imprudence. After the accused had pleaded “not guilty” to the
charge and before the hearing of the case, the private prosecutor filed a
memorandum raising the question of the jurisdiction of the justice of the peace
court to try the case on the ground that the amount of the fine imposable upon
the accused, aside from the penalty for the physical injuries committed, is
beyond the jurisdiction of the justice of the peace court. On the strength of
this memorandum, the justice of the peace court issued an order on November 24,
1958 declaring itself without jurisdiction to try the case, and forwarding it to
the Court of First Instance for further proceedings.

In the latter Court, a similar information was filed by the provincial fiscal
against the accused. Before the arraignment of the accused, however, 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, in an order dated January 21, 1959, declared itself without
jurisdiction over the complex crime charged 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, therefore, ordered the
return of the case to the justice of the peace for trial on the merits. From
this order, the provincial fiscal appealed to this Court.

We find the appeal well-taken, for this case comes squarely under the rule
laid down by us in Angeles, et al., vs. Jose, 96 Phil., 151, 50 Off. Gaz.
No. 12, 5764, wherein we held that:

“‘The above-quoted provision (Art. 365, par. 3, Revised Penal Code) simply
means that if there ia 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 bo 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 line can not
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.

Bengzon, C.J.,
Padilla, Bautista Angelo, Labrador, Concepcion, Barrera, Paredes, and
Dizon, JJ., concur.