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PEOPLE v. LIBERTAD LAGON

FACTS:

Libertad Lagon was charged with estafa for allegedly issuing a bounced check. The criminal information was filed with the City Court of Roxas City in 1976. However, the court dismissed the case because the penalty for the offense had been increased and was beyond the court's authority to impose. The court held that jurisdiction is determined by the law in force at the time of the institution of the action, not at the time of the commission of the crime. At the time of the commission of the offense, the penalty fell within the jurisdiction of the City Court. However, by the time the information was filed, the penalty had been increased, thus the case should be filed in the proper court. The People, in their Petition for Review, argued that the City Court had jurisdiction and erred in dismissing the case. The Office of the Solicitor General agreed with the position taken by the Assistant City Fiscal that the City Court had jurisdiction. The Court ruled that the City Court did not commit reversible error in dismissing the case, and jurisdiction over the case pertained to the Court of First Instance of Roxas City. It emphasized that subject matter jurisdiction is determined by the court's authority to impose the penalty under the applicable statute at the time of the commencement of the case. The court retained jurisdiction even if a lesser penalty was proven during trial. Thus, if the case is refiled, the Regional Trial Court would have subject matter jurisdiction even if a lower penalty should be imposed.

ISSUES:

  1. Did the City Court of Roxas City have jurisdiction over the criminal case?

  2. Did the City Court commit reversible error in dismissing the criminal information?

RULING:

  1. Yes, the City Court of Roxas City had jurisdiction over the criminal case. At the time of the commission of the offense, the penalty imposable fell within the jurisdiction of the City Court.

  2. No, the City Court did not commit reversible error in dismissing the criminal information. The City Court correctly determined that it did not have authority to impose the increased penalty under the amended law. The subject matter jurisdiction of a court is determined by the law in effect at the time of the commencement of the criminal action. Therefore, the case should be refiled in the proper Regional Trial Court.

PRINCIPLES:

  • The subject matter jurisdiction of a court in criminal cases is determined by the penalty imposable under the applicable statute at the time of the commencement of the criminal action.

  • Jurisdiction is retained by the court in which the information is filed, even if the evidence proves a lesser offense than that charged.

  • Penal laws cannot be applied retroactively unless they favor the person guilty of a felony, who is not a habitual criminal.