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Secs. 20 & 32, BP 129 as amended by RA 7691 show that the court in which the complaint is presented has
jurisdiction, that court must assume jurisdiction. Once
Jurisdiction is measured by the law at the time of the jurisdiction is acquired by the court in which the information
commencement of criminal action. is filed, it is retained regardless whether the evidence proves
a lesser offense than that charged in the information
PEOPLE OF THE PHILIPPINES, petitioner, vs. LIBERTAD Should the criminal information be refiled in the proper
LAGON AND HON. JUDGE ISIDRO O. BARRIOS, AS court, that is, the proper Regional Trial Court, that court may
PRESIDING JUDGE OF THE CITY COURT OF ROXAS CITY, not impose that more onerous penalty upon private
respondents. respondent Libertad LagonBut the Regional Trial Court
RE SUBJECT MATTER JURISDICTION would remain vested with subject-matter jurisdiction to try
It is firmly settled doctrine that the subject matter and decide the (refiled) case even though the penalty properly
jurisdiction of a court in criminal law matters is properly imposable, given the date of the commission of the offense
measured by the law in effect at the time of the charged, should be the lower penalty originally provided for
commencement of a criminal action, rather than by the law which is otherwise within the exclusive jurisdiction of the
in effect at the time of the commission of the offense charged. City Court of Roxas City.

RE VIOLATION OF THE RULE AGAINST RETROACTIVITY Facts:


OF PENAL LAWS
In the first place, subject-matter jurisdiction in criminal o Information was filed on 7 July 1976 with the City Court of
cases is determined by the authority of the court to impose Roxas City (MTC), against lagon for the crime of estafa. The
the penalty imposable under the applicable statute given the accused allegedly issued a check as payment for goods,
allegations of a criminal information. knowing that she did not have sufficient funds to cover the
check.
The issue here is one of jurisdiction, of a court's legal o Trial ensued, however, the court dismissed the information
competence to try a case ab origine. In criminal prosecutions, on the ground that the penalty prescribed by law for the
it is settled that the jurisdiction of the court is not offense charged was beyond the court's authority to impose.
determined by what may be meted out to the offender after o The judge held that the jurisdiction of a court to try a
trial, or even by the result of the evidence that would be criminal action is determined by the law in force at the time
presented at the trial, but by the extent of the penalty which of the institution of the action, and not by the law in force
the law imposes for the misdemeanor, crime or violation at the time of the commission of the crime.
charged in the complaint. If the facts recited in the complaint o At the time of the commission of the offense1 in April 1975,
and the punishment provided for by law are sufficient to jurisdiction was vested with the city court, but at the time

1The law governing the subject matter jurisdiction of municipal and or imprisonment for not more than six (6) years or fine not
city courts in criminal cases in 1975 and 1976, "[m]unicipal judges in exceeding P6,000.00 or both.
the capitals of provinces and sub-provinces and judges of city courts
It appears that at the time of the commission of the offense charged
shall have like jurisdiction as the Court of First Instance to try parties
on 5 April 1975, the penalty imposable for the offense charged under
charged with an offense within their respective jurisdictions, in which
paragraph 2(d) in relation to the third sub-paragraph of the first
the penalty provided by law does not exceed prision correccional
paragraph, Article 315 of the Revised Penal Code, was arresto mayor
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the criminal action was filed, the Article 315 of the RPC was the result of the evidence that would be presented at the trial,
amended and the penalty imposable upon a person accused but by the extent of the penalty which the law imposes for the
thereunder increased, which penalty was beyond the City misdemeanor, crime or violation charged in the complaint. If
Court's authority to impose. Hence, its dismissal without the facts recited in the complaint and the punishment provided
prejudice to its being refiled in the proper court. for by law are sufficient to show that the court in which the
complaint is presented has jurisdiction, that court must
Hence, this petition for review. assume jurisdiction. Once jurisdiction is acquired by the court
Issue: WON the city court of Roxas City has jurisdiction over in which the information is filed, it is retained regardless
the criminal case. whether the evidence proves a lesser offense than that charged
in the information
Held: No.
Should the criminal information be refiled in the proper court,
Ratio: It is firmly settled doctrine that the subject matter that is, the proper Regional Trial Court, that court may not
jurisdiction of a court in criminal law matters is properly impose that more onerous penalty upon private respondent
measured by the law in effect at the time of the commencement Libertad Lagon
of a criminal action, rather than by the law in effect at the time
of the commission of the offense charged. Thus, it is the CFI of But the Regional Trial Court would remain vested with subject-
Roxas City which has jurisdiction, considering that P.D. No. matter jurisdiction to try and decide the (refiled) case even
818 had increased the imposable penalty for the offense though the penalty properly imposable, given the date of the
charged in Criminal Case No. 7362 to a level in excess of the commission of the offense charged, should be the lower penalty
maximum penalty which a city court could impose. originally provided for which is otherwise within the exclusive
jurisdiction of the City Court of Roxas City.
Issue (2): Would the application of said doctrine not amount to
disregard of the rule against retroactivity of penal laws?
Held: No.
Ratio: In the first place, subject-matter jurisdiction in criminal
cases is determined by the authority of the court to impose the
penalty imposable under the applicable statute given the
allegations of a criminal information.
The issue here is one of jurisdiction, of a court's legal
competence to try a case ab origine. In criminal prosecutions,
it is settled that the jurisdiction of the court is not determined
by what may be meted out to the offender after trial, or even by

in its maximum period to prision correccional in its minimum At the time of the institution of the criminal prosecution on 7 July
period; at that time therefore, the offense clearly fell within the 1976, the penalty imposable for the offense charged in Criminal Case
jurisdiction of the City Court of Roxas City. No. 7362 had been increased by P.D. No. 818 (effective 22 October
1975) to prision mayor in its medium period.
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Secs. 20 & 32, BP 129 as amended by RA 7691 o Before the passage of BP 129, an information for simple
seduction was filed with the City Court of Dipolog (MTC)
Jurisdiction over the subject matter is determined by the law in against Vilmor Icao.
force at the time of the commencement of the criminal action. o Accused moved to quash the information on the ground
Exclusive Original Jurisdiction vested on MTC. that the City Court had no jurisdiction to try the offense,
and the fiscal who filed the information had no authority to
CORA LEGADOS, represented by ROSA LEGADOS, and HON. do so.
JESUS ANGELES, petitioners, vs. HON. DOROTEO DE o The Court denied the motion and scheduled the case for
GUZMAN, Judge, CFI, Br. II, Zamboanga, VILMOR ICAO, trial on the merits.
represented by his mother, SOFIA L. ICAO, respondents. o Icao thereupon instituted an action of prohibition with the
RE JURISDICTION CFI of Zamboanga (RTC).
The writ of prohibition was, of course, correctly issued by the Issue: WON the prohibition was properly issued.
respondent Judge, being consistent with the doctrine
obtaining at the time, i.e., that an inferior court had no Held: Yes.
jurisdiction over the crime of simple seduction. But, as
already pointed out, the doctrine has since been changed. Ratio: The writ of prohibition was, of course, correctly issued
Now, the offense is explicitly declared by law to be within the by the respondent Judge, being consistent with the doctrine
exclusive original jurisdiction, no longer of Courts of First obtaining at the time, i.e., that an inferior court had no
Instance (since abolished and replaced by Regional Trial jurisdiction over the crime of simple seduction. But, as already
Courts), but of Metropolitan Trial Courts, Municipal Trial pointed out, the doctrine has since been changed. Now, the
Courts, and Municipal Circuit Trial Courts. offense is explicitly declared by law to be within the exclusive
original jurisdiction, no longer of Courts of First Instance (since
abolished and replaced by Regional Trial Courts), but of
Facts: Metropolitan Trial Courts, Municipal Trial Courts, and
Municipal Circuit Trial Courts.
The Proviso in Section 32 of BP 1292, effective August 14, 1981
altered and superseded the long standing doctrine which
provides that an inferior court had no jurisdiction over the
crime of simple seduction although the penalty imposed is
arresto mayor because conviction thereof carried with it the
liability imposed by Article 345 of the Revised Penal Code to
acknowledge and give support to the offspring.

2 Metropolitan Trial Courts, Municipal Trial Courts, and Municipal both such fine and imprisonment, regardless of other imposable
Circuit Trial Courts 1 "(e)xclusive original jurisdiction over all accessory or other penalties, including the civil liability arising from
offenses punishable with imprisonment of not exceeding four years such offenses or predicated thereon, irrespective of kind, nature,
and two months, or a fine of not more than four thousand pesos, or value, or amount thereof.
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Secs. 20 & 32, BP 129 as amended by RA 7691 the Judiciary Act defining the jurisdiction of other courts
(such as the Court of First Instance) which is a general law.
Moreover, a general law cannot repeal or amend by
RTC has exclusive original jurisdiction over libel cases. implication a specific provision or a special law. Otherwise
PEOPLE OF THE PHILIPPINES, petitioner, vs. METROPOLITAN stated: a subsequent statute, general in character as to its
TRIAL COURT OF QUEZON CITY, Branch 32, and ISAH V. terms and operation, is not to be construed as repealing a
RED, respondents. special or specific enactment, unless the legislative purpose
to do so is manifested. This is so, even if the provisions of
RE JURISDICTION the latter are sufficiently comprehensive to include what
The contention that R.A. No. 7691 divested the Regional Trial was set forth in the special act.
Courts of jurisdiction to try libel cases cannot be sustained. o Judge denied the motion. It opined that "Rep. Act No. 7691,
While libel is punishable by imprisonment of six months and which took effect on April 15, 1994, would partake of the
one day to four years and two months (Art. 360, RPC) which nature of a 'modern' law which impliedly repeals an
imposable penalty is lodged within the Municipal Trial 'ancient' law (the Revised Penal Code) which is of 1932
Courts jurisdiction under R.A. No. 7691 (Sec. 32 [2]), said vintage, which is inconsistent with the later law **; (and
law, however, excludes therefrom ** cases falling within the that) if the repeal makes the penalty lighter in the new law,
exclusive original jurisdiction of the Regional Trial Courts. the new law shall be applied.
Issue: Whether it is the Regional Trial Court, or the
Facts: Metropolitan Trial Court or other first level court which has
exclusive original jurisdiction over criminal actions of libel.
o An information for libel was filed against Isah V. Red in the
Regional Trial Court of Quezon City. Held: RTC.
o Accused filed a motion to quash the information on the
Ratio: The contention ** that R.A. No. 7691 divested the
ground that the RTC had no jurisdiction of the offense.
Regional Trial Courts of jurisdiction to try libel cases cannot be
o The judge granted the motion and remanded the case to the
sustained. While libel is punishable by imprisonment of six
MTC.3
months and one day to four years and two months (Art. 360
o The private prosecutor filed a motion to remand the case
Revised Penal Code) which imposable penalty is lodged within
back to the RTC. He invoked Article 360 of the Revised
the Municipal Trial Courts' jurisdiction under R.A. No. 7691
Penal Code.4 And argued that laws vesting jurisdiction
(Sec. 32 [2]), said law, however, excludes therefrom' ** cases
exclusively with a particular court (such as the Court of Tax
falling within the exclusive original jurisdiction of the Regional
Appeals) are special in character, and should prevail over
Trial Courts. Regional Trial Courts have the exclusive

3 (u)nder Section 2 of R.A. No. 7691, which took effect on April 15, 4 The criminal action and civil action for damages in case of written
1994, exclusive original jurisdiction over 'all offenses punishable defamation, as provided for in this chapter, shall be filed
with imprisonment not exceeding six (6) years, irrespective of the simultaneously or separately with the Court of First Instance of the
amount of fine, and regardless of other imposable accessory or other province or city where the libelous article is printed and first
penalties, including the civil liability arising from such offenses or published or where any of the offended parties actually resides at the
predicated thereon, irrespective of kind, nature, value or amount time of the commission of the offense.
thereof' is vested in the Municipal Trial Court.
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jurisdiction over libel cases, hence, the expanded jurisdiction


conferred by R.A. 7691 to inferior courts cannot be applied to
libel cases.
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RA 8249 (Sandiganbayan) o Alas filed a motion to quash the informations for lack of
jurisdiction.
To determine jurisdiction of the Sandiganbayan; Disregard what o The respondent court ruled that PPSB was a private
mode of creation and disregard also the salary grade. corporation and that its officers, particularly herein
PEOPLE OF THE PHILIPPINES, petitioner, vs. THE respondent Alas, did not fall under Sandiganbayan
HONORABLE SANDIGANBAYAN (Fifth Division) and EFREN L. jurisdiction. The Sandiganbayan has jurisdiction only over
ALAS, respondents. public officers unless private persons are charged with
them in the commission of the offenses.
RE JURISDICTION OF SB OVER OFFICERS OF GOCCS o The records disclosed that while Philippine Postal Savings
WITH ORIGINAL CHARTER AND GOCCS ORGANIZED Bank is a subsidiary of the Philippine Postal Corporation
UNDER THE CORPORATION CODE. which is a government owned corporation, the same is not
Congress, pursuant to its authority vested under the 1987 created by a special law. It was organized and incorporated
Constitution, enacted RA 7975[8] maintaining the under the Corporation Code for profit. Thus, its officers and
jurisdiction of the Sandiganbayan over presidents, directors employees are not covered by the GSIS and are under the
or trustees, or managers of government-owned or controlled SSS law, and actions for reinstatement and backwages are
corporations without any distinction whatsoever. not within the jurisdiction of the Civil Service Commission
(g) Presidents, directors or trustees, or managers of but by the National Labor Relations Commission (NLRC).
government-owned or controlled corporations, state o People - argues in further defining the jurisdiction of the
universities or educational institutions or foundations. Sandiganbayan, RA 8249 did not make a distinction as to
the manner of creation of the government-owned or
controlled corporations for their officers to fall under its
Facts:
jurisdiction. Hence, being President and Chief Operating
o The Ombudsman filed two separate informations for Officer of the PPSB at the time of commission of the crimes
violation of AGCPA from alleged anomalous advertising charged, respondent Alas came under the jurisdiction of the
contracts entered into by Alas, in his capacity as President Sandiganbayan.
and Chief Operating Officer of the Philippine Postal Savings
Bank (PPSB), with Bagong Buhay Publishing Company
which purportedly caused damage and prejudice to the Issue: Does the Sandiganbayan have jurisdiction over
government, filed with the Sandiganbayan. presidents, directors or trustees, or managers of government-
owned or controlled corporations5 organized and incorporated

5 Section 2(13) of EO 292 6 defines government-owned or controlled proprietary in nature, and owned by the government directly or
corporations as follows: indirectly or through its instrumentalities either wholly, or where
Sec. 2. General Terms Defined Unless the specific words of the applicable as in the case of stock corporations to the extent of at
text or the context as a whole or a particular statute, shall require a least 51% of its capital stock: provided, that government owned or
different meaning: controlled corporations may be further categorized by the
xxx xxx xxx department of the budget, the civil service commission and the
(13) government owned or controlled corporations refer to any commission on audit for the purpose of the exercise and discharge of
agency organized as a stock or non-stock corporation vested with their respective powers, functions and responsibilities with respect to
functions relating to public needs whether governmental or such corporations.
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under the Corporation Code for purposes of the provisions of


RA 3019, otherwise known as the Anti-Graft and Corrupt
Practices Act.
Held: Yes
Ratio: From the foregoing, PPSB fits the bill as a government-
owned or controlled corporation, and organized and
incorporated under the Corporation Code as a subsidiary of the
Philippine Postal Corporation (PHILPOST). More than 99% of
the authorized capital stock of PPSB belongs to the government
while the rest is nominally held by its incorporators who
are/were themselves officers of PHILPOST. The creation of
PPSB was expressly sanctioned by Section 32 of RA 7354,
otherwise known as the Postal Service Act of 1992, for purposes
of, among others, "to encourage and promote the virtue of thrift
and the habit of savings among the general public, especially
the youth and the marginalized sector in the countryside . . ."
and to facilitate postal service by "receiving collections and
making payments, including postal money orders."
Congress, pursuant to its authority vested under the 1987
Constitution, enacted RA 7975[8] maintaining the jurisdiction
of the Sandiganbayan over presidents, directors or trustees, or
managers of government-owned or controlled corporations
without any distinction whatsoever.
The legislature, in mandating the inclusion of "presidents,
directors or trustees, or managers of government-owned or
controlled corporations" within the jurisdiction of the
Sandiganbayan, has consistently refrained from making any
distinction with respect to the manner of their creation.
The deliberate omission, in our view, clearly reveals the
intention of the legislature to include the presidents, directors
or trustees, or managers of both types of corporations within
the jurisdiction of the Sandiganbayan whenever they are
involved in graft and corruption. Had it been otherwise, it could
have simply made the necessary distinction. But it did not.