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Cuyos vs.

Garcia
G.R. No. L-46934, April 15, 1988
FACTS:
Petitioner Alfredo Cuyos was charged with homicide with multiple serious
physical injuries and damage to property through reckless imprudence before the
Municipal Court of San Fernando, Pampanga. Cuyos entered a plea of not guilty at
the arraignment and the judge set the case for trial, but before it could commence,
petitioner filed a Motion to Remand the Case to the Court of First Instance. Cuyos
claimed that there is lack of jurisdiction on the part of the Municipal Court and
contended that the damages suffered by the Volkswagen he hit amounted to
P18,000.00. He argued that under Art. 365, par. 3 of the Revised Penal Code, the
crime would carry a fine in an amount ranging from the amount of the damage to
three times the value of the damage alleged (i.e. 3 x P18,000.00=P54,000.00).
Under Sec. 87 of the Judiciary Act of 1948, the Municipal Court of Pampanga only
has jurisdiction over offenses punishable by a fine not exceeding P6,000.00. Cuyos
filed an Urgent Motion to Postpone the Trial. The municipal judge denied the motion
to transfer and set the case for trial. Cuyos verbal motion for reconsideration was
denied. Hence, the present petition for certiorari.
ISSUE:
Whether or not the respondent Municipal Court of San Fernando, Pampanga
has jurisdiction to try the case against Cuyos.
HELD:
The Court agrees with the position of the Solicitor General that the Municipal
Court has no jurisdiction to try the present case. The case at bar involves a complex
crime of homicide, multiple serious physical injuries and damage to property
resulting from reckless imprudence. Art. 365, par.2 of the Revised Penal Code
provides that the penalty imposable upon petitioner, if found guilty of homicide
through reckless imprudence would be prision correccional in its medium and
maximum periods. At the time the complaint was filed, the Municipal Court had
jurisdiction to impose a penalty of imprisonment not exceeding six(6) years or a fine
not exceeding P6,000.00 or both. Thus, because the penalty for damage to property
through imprudence or negligence as provided in Art. 365 of the Revised Penal Code
is, a fine ranging from the amount equal to the value of damages to three times
such value, the case must be forwarded to the Court of First Instance. Art. 365
simply means that if there is only damage to property, the amount fixed shall be
imposed, but if there is also physical injuries, there should be an additional penalty
for the latter. The applicable rule on allocation of jurisdiction on cases involving
cases of reckless imprudence resulting in homicide or physical injuries is
summarized by justice Barrera. Barrera stated that in such cases, Art. 48 of the
Revised Penal Code is applicable, but there may be cases when the imposable
penalty is within the jurisdiction of the Municipal Court, while the fine is under the
jurisdiction of the Court of First Instance. Since the information cannot be split into
two, the jurisdiction of the court is determined by the fine imposable for the damage
to property resulting from the reckless imprudence. The maximum fine imposable

for the crime in this case is P54,000.00 and the maximum imprisonment for
homicide is six (6) years. Therefore, the criminal charge falls outside the jurisdiction
of the Municipal Court and within the jurisdiction of the Regional Trial Court. The
order of the Municipal Court is SET ASIDE as null and void and the Temporary
Restraining Order is made PERMANENT.