Jurisdiction over Crimes Punishable Only by a Fine - Prof. Manuel Riguera

Source - https://legisperit.com/2022/08/17/jurisdiction-over-crimes-punishable-only-by-a-fine/


"Jurisdiction over Crimes Punishable Only by a Fine

Supreme Court Administrative Circular No. 09-94 (14 June 1994) provides that it is the Metropolitan Trial Courts, Municipal Trial Courts, or Municipal Circuit Trial Courts (MTCs) which have jurisdiction over crimes punishable only by a fine, where such fine does not exceed ₱4,000.

It is axiomatic that the Supreme Court does not have the power to lay down rules regarding subject-matter jurisdiction. SC Administrative Circular No. 09-94 was thus anchored on the original provision of Section 32(2) of B.P. Blg. 129 (prior to its amendment by R.A. No. 7691) which provides that the MTCs shall have jurisdiction over crimes punishable only by a fine not exceeding ₱4,000. Hence, a crime punishable only by a fine exceeding ₱4,000 is within the jurisdiction of the Regional Trial Court (RTC).

However, the Rules on Expedited Procedure in the First Level Courts (effective 11 April 2022) provide that “[a]ll … criminal cases where the penalty prescribed by law for the offense charged is … a fine not exceeding Fifty Thousand Pesos (₱50,000.00)” shall be governed by the Rule on Summary Procedure (Section 1[B][5]). The Rule on Summary Procedure of course applies exclusively to cases before the MTCs. In effect, the REPFLC increased the jurisdictional amount provided for in Administrative Circular No. 09-94 from ₱4,000 to ₱50,000. Hence, from the text of the REPFLC, a crime punishable only by a fine exceeding ₱4,000 but not ₱50,000 would fall within the MTC’s jurisdiction.

It is submitted however with due respect that the REPFLC cannot effectively increase the jurisdictional amount to ₱50,000. Unlike SC Administrative Circular No. 09-94 which was anchored on B.P. Blg. 129, Section 1(B)(5) of the REPFLC is bereft of statutory mooring. A legislative amendment of Section 32(2) of B.P. Blg. 129 would be required to increase the jurisdictional amount for offenses punishable by fine only. It is thus opined that the RTCs retain jurisdiction over offenses punishable only by a fine exceeding ₱4,000.

In line with the foregoing observations, it is also submitted that Section 1(B)(5) of the REPFLC be amended as follows:

“All other criminal cases where the penalty prescribed by law for the offense charged is imprisonment not exceeding one (1) year or where the prescribed penalty consists only of a fine not exceeding Four Thousand Pesos (₱4,000.00). In offenses involving damage to property through criminal negligence under Article 365 of the Revised Penal Code, this Rule shall govern where the imposable fine does not exceed One Hundred Fifty Thousand Pesos (₱150,000.00).”"