People v Lagon

Doctrine: Subject-matter jurisdiction is determined not at the time of the commission of the offense but at
the time of the filing of the criminal information.
Case Summary: The City Court dismissed a criminal information for estafa because it believed it did not
have jurisdiction over the offense after an amendment in the law. The judge held that jurisdiction is
determined by the law in force at the time of the institution of the action and not at the time of the
commission of the offense. The SC agreed that the case should be refiled with the RTC since the latter has
acquired subject-matter jurisdiction. Nevertheless, the RTC may not impose the higher penalty because of
the rule against retroactivity of penal laws.

Facts:
Accused Lagon was charged with estafa in the City Court of Roxas City for allegedly issuing a check as
payment for goods purchased, knowing that she did not have sufficient funds to cover the check. However,
the court dismissed the information on the ground that the penalty prescribed by law for the offense was
beyond its authority to impose. The judge held that the jurisdiction of a court to try a criminal action is
determined by the law at the time of the institution of the action, not the commission of the crime.
At the time of its commission, jurisdiction over the offense was vested in the City Court. However,
the information was filed after the amendment of the RPC by PD 818 which imposed a penalty for the
offense beyond the court’s authority to impose. Hence, the People filed a Petition for Review, arguing that
the City Court had jurisdiction over the criminal case.
Issue:
Whether jurisdiction is acquired from the time of the commission of the offense or at the time the criminal
information was filed
Held:
Petition dismissed.
It is well-settled that subject matter jurisdiction of a court in criminal law matters is measured by
the law in effect at the time of the commencement of a criminal action, rather than by the law in effect at
the time of the commission of the offense.
Given this, jurisdiction over the case should pertain to the RTC since PD 818 increased the
imposable penalty for the offense to a level in excess of the minimum which a city court could impose.
Although the RTC has subject-matter jurisdiction over the case, the penalty it may impose should be the
penalty originally provided for and not that of PD 818. This is to avoid a violation of the rule against
retroactivity of penal laws.