People v Dacuycuy

People v Dacuycuy Facts: Private respondents were charged with violation of RA 4670 (Magna Carta for Public School Teachers. They also charged constitutionality of Sec.32 (…be punished by a fine of not less than P100 nor more than P1000, or by imprisonment, in the discretion of the court.) of said R.A on grounds that it a.) imposes a cruel and unusual punishment, b.) constitutes an undue delegation of legislative power. Judge Dacuycuy ruled that the said section is a matter of statutory construction and not an undue of delegation of legislative power. Issue: W/N Sec. 6 constitutes undue delegation of legislative power and is valid. Held: NOT VALID! The duration of penalty for the period of imprisonment was left for the courts to determine as if the judicial department was a legislative dep’t. The exercise of judicial power not an attempt to use legislative power or to prescribe and create a law but is an instance of the admin. of justice and the app. of existing laws to the facts of particular cases. Said section violates the rules on separation of powers and nondelegability of legislative powers PEOPLE VS DACUYCUY 173 SCRA 90 (1989) PETITIONER: PEOPLE OF THE PHILIPPINES RESPONDENT: JUDGE AUXENCIO C. DACUYCUY, CELESTINO S. MATONDO, SEGUNDINO A. CAVAL, AND CIRILIO M. ZANORIA FACTS: On April 4, 1975, private respondents Celestino S. Matondo, Segundino A. Caval, and Cirilio M. Zanoria, public school officials from Leyte were charged before the Municipal Court of Hindang, Leyte for violating Republic Act No. 4670 (Magna Carta for Public School Teachers). The respondents pleaded not guilty and petitioned for certeriori and prohibition with preliminary injuction before the Court of First Instance of Leyte, Branch VII alleging that: a. The Municipal Court of Hindang has no jurisdiction over the case due to the correctional nature of the penalty of imprisonment (as state in Sec. 32 of R.A. No. 4670) prescribed for the offense b. Section 32 of R.A. No. 4670 is unconstitutional because, (1) the term of imprisonment is unfixed and may run to reclusion perpetua; and (2) it constitutes an undue delegation of legislative power, the duration of the penalty of imprisonment being solely left to the discretion of the court as if the latter were the legislative department of the Government.

On March 30, 1976, the petition was transferred to Branch IV where the respondent Judge, Judge Dacuycuy ruled that R.A. No. 4670 is valid and constitutional but cases for its violation fall outside of the jurisdiction of municipal and city courts.

ISSUE: Whether or not Repbulic Act No. 4670 is unconstitutional. Whether or not the municipal and city courts have jurisdiction over the case. HELD: Yes, Republic Act No. 4760 is unconstitutional. Section 32 violates the constitutional prohibition against undue delegation of legislative power by vesting in the court the responsibility of imposing a duration on the punishment of imprisonment, as if the courts were the legislative department of the government. Yes, the municipal and city courts have jurisdiction over the case. Republic Act. No. 296, as amended by Republic Act No. 3828, considers crimes punishable by fine of not more than Php 3,000.00 fall under the original jurisdiction of municipal courts. Decision: The decision and resolution of respondent Judge (Judge Dacuycuy) are hereby REVERSED and SET ASIDE. Criminal Case No. 555 filed against private respondents herein is hereby ordered to be remanded to the Municipal Trial Court of Hindang, Leyte for trial on the merits.