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People vs. Judge Ocaya Case Digest


The jurisdiction of the court in a criminal case is determined by the allegations in the information or criminal complaint, and not by the result of the evidence presented at the trial, much less by the trial judge’s personal appraisal of the affidavits and exhibits attached by the fiscal to the record of the case. Moreover, once the jurisdiction attaches to the person and subject matter of the litigation, the subsequent happening of events, although they are of such a character as would have prevented jurisdiction from attaching in the first instance, will not operate to oust jurisdiction already attached.

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Facts: 

A charge of serious physical injuries was filed against private respondents but Judge Ocaya after scanning the records and noting that the medical certificate stated that the injuries would require medical attention from seven (7) to ten (10) days and therefore may either be slight or less serious physical injuries only and without receiving the evidence or hearing the witnesses, precipitately dismissed the information for lack of jurisdiction on the erroneous notion that in physical injury cases, the duration of the treatment of the injury inflicted on the victim as indicated in the medical certificate determines the jurisdiction of the court.

The MR was denied; hence, the fiscal filed the petition for certiorari.


Issue:

Did Judge Ocaya committed a grave abuse of discretion in precipitately dismissing the case for alleged lack of jurisdiction?


Held:

Yes. It is elemental that the jurisdiction of a court in criminal cases is determined by the allegations of the information or criminal complaint and not by the result of the evidence presented at the trial, much less by the trial judge’s personal appraisal of the affidavits and exhibits attached by the fiscal to the record of the case without hearing the parties and their witnesses nor receiving their evidence at a proper trial.

It is equally elementary that the mere fact that evidence presented at the trial would indicate that a lesser offense outside the trial court’s jurisdiction was committed does not deprive the trial court of its jurisdiction which had vested in it under the allegations of the information as filed since" (once) the jurisdiction attaches to the person and subject matter of the litigation, the subsequent happening of events, although they are of such a character as would have prevented jurisdiction from attaching in the first instance, will not operate to oust jurisdiction already attached."

Indeed, the Solicitor General has aptly commented that "the dismissal of the case had only resulted in duplication of work and wasted time in the remand of records when respondent trial judge dismissed the instant case for want of jurisdiction, when it could have immediately proceeded to arraign the accused and try him."

The SC nullified the questioned orders and ordered the remand of the case for further proceedings to another branch of the same Court of First Instance since it is doubtful that the State and offended party may expect a fair and impartial hearing and determination of the case in view of the respondent’s erroneous pre-conceptions and pre-delictions which had adversely prejudged the case for serious physical injuries as one merely of slight or less serious physical injuries. (People vs. Ocaya, G.R. No. L-47448. May 17, 1978)

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