Consolacion P. Mangila v · G.R. L-24735

Petitioner: Consolacion P. Mangila
Respondent: Judge Lantin
Citation: G.R. No. L-24735
Court: Supreme Court
Division: En Banc
Ponente: Sanchez, J.
Decided: October 31, 1969

Jurisdiction over serious slander case and whether criminal action requires express complaint from offended parties

Summary

Supreme Court case involving jurisdictional challenge to serious slander prosecution. Petitioner Mangila challenged Court of First Instance jurisdiction, claiming case belonged to Municipal Court and required express complaint from offended parties. Court ruled that both CFI and Municipal Court have concurrent jurisdiction over crimes punishable by more than 6 months but not exceeding 3 years imprisonment. Since serious slander carries penalty of arresto mayor maximum to prision correccional minimum, CFI had proper jurisdiction. Court also held Article 360 RPC requiring express complaint did not apply since imputed acts (prostitution, premarital relations) either involve crimes prosecutable de officio or are not crimes requiring private complaint. Petition dismissed, allowing criminal prosecution to proceed.

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By Intellegal Editorial Board · October 31, 1969

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