Cuyos vs. GarciaG . R . N o .

L - 4 6 9 3 4 A p r i l 1 5 , 1 9 8 8 FACTS:
Petitioner Alfredo Cuyos was charged
with homicidew i t h m u l t i p l e s e r i o u s p h y s i c a l i n j u r i e s a n d d a m a g e t o proeperty through reckless
imprudence before the MunicipalCourt of San Fernando, Pampanga. Cuyos entered a plea of not guilty at the
arraignment and the judge set the case fortrial, but before it could commence, petitioner filed a Motionto
Remand the Case to the Court of First Instance. Cuyos claimed that there is lack of jurisdiction on
the part of theMunicipal Court and contended that the damages sufferedby the Volkswagen he hit
amounted to P18,000.00. Heargued that under Art. 365, par. 3 of the Revised PenalCode, 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 87 of the Judiciary Act of 1948, the
MunicipalC o u r t o f P a m p a n g a o n l y h a s j u r i s d i c t i o n o v e r o f f e n s e s punishable by a fine not
exceeding P6,000.00. Cuyos filedan Urgent Motion to Postpone the Trial. The municipal judgedenied 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 caseagainst Cuyos
HELD:
The Court agrees with the position of the Solicitor General that the Municipal Court has no
jurisdiction to trythe present case. The case at bar involves a complex crimeof homicide, multiple serious
physical injuries and damageto property resulting from reckless imprudence. Art. 365,par.2 of the Revised
Penal Code provides that the
penaltyi m p o s a b l e u p o n p e t i t i o n e r , i f f o u n d g u i l t y o f h o m i c i d e through reckless imprudence,
would be prision correccionali n i t s m e d i u m a n d m a x i m u m p e r i o d s . At t h e t i m e t h e complaint
was filed, the Municipal Court had jurisdiction
toi m p o s e a p e n a l t y o f i m p r i s o n m e n t n o t e x c e e d i n g s i x (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 amountequal to the value of damages to
three times such value, the case must be forwarded to the Court of First Instance.A r t . 3 6 5 s i m p l y
m e a n s t h a t i f t h e r e i s o n l y d a m a g e t o property, the amount fixed shall be imposed, but if there
isalso physical injuries, there should be an additional penaltyfor the latter. The applicable
rule on allocation of jurisdiction oncases involving cases of reckless imprudence resulting
inh o m i c i d e o r p h y s i c a l i n j u r i e s i s s u m m a r i z e d b y j u s t i c e Barrera. Barrera stated that in
such cases, Art. 48 of theRevised Penal Code is applicable, but there may be caseswhen the
imposable penalty is within the jurisdiction of theMunicipal Court, while the fine is under the
jurisdiction of the Court of First Instance. Since the information cannot besplit into two, the jurisdiction of
the court is determined bythe fine imposable for the damage to property resultingfrom the reckless
imprudence. The maximum fine imposablefor the crime in this case is P54,000.00 and the
maximumimprisonment for homicide is six (6) years. Therefore, thecriminal charge falls outside the
jurisdiction of the MunicipalCourt and within the jurisdiction of the Regional Trial Court.

The order of the Municipal Court is SET ASIDE as nulland void and the Temporary Restraining
Order is made PERMANENT