People v. Dacuycuy: Imprisonment, in The Discretion of The Court. (Emphasis Supplied)

People v.
Dacuycuy
Doctrines/Principles:
The disputed section of Republic Act No. 4670 provides:
Sec. 32. Penal Provision. — A person who shall wilfully interfere with, restrain or coerce any
teacher in the exercise of his rights guaranteed by this Act or who shall in any other manner
commit any act to defeat any of the provisions of this Act shall, upon conviction, be punished by
a fine of not less than one hundred pesos nor more than one thousand pesos, or by
imprisonment, in the discretion of the court. (Emphasis supplied).
Two alternative and distinct penalties are consequently imposed, to wit: (a) a fine ranging from
P100.00 to P1,000.00; or (b) imprisonment. It is apparent that the law has no prescribed period
or term for the imposable penalty of imprisonment. While a minimum and maximum amount for
the penalty of fine is specified, there is no equivalent provision for the penalty of imprisonment,
although both appear to be qualified by the phrase "in the discretion of the court.
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 injunction 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 20, 1976 – the petition was transferred to Branch IV where the respondent
Judge, Judge Dacuycuy, ruled that RA No. 4670 is valid and constitutional but cases for
its violation fall outside of the jurisdiction of municipal and city courts.
ISSUES:
1.) WON the municipal and city courts have jurisdiction over violation of RA No. 4670.
- 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.
2.) WON Section 32 of said RA No. 4670 is constitutional.

- NO, RA No. 4670 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.
Held:
WHEREFORE, the decision and resolution of respondent judge 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.
Ratio:
In the case under consideration, the respondent judge erroneously assumed that since the
penalty of imprisonment has been provided for by the legislature, the court is endowed with the
discretion to ascertain the term or period of imprisonment. We cannot agree with this postulate.
It is not for the courts to fix the term of imprisonment where no points of reference have been
provided by the legislature. What valid delegation presupposes and sanctions is an exercise of
discretion to fix the length of service of a term of imprisonment which must be encompassed
within specific or designated limits provided by law, the absence of which designated limits well
constitute such exercise as an undue delegation, if not-an outright intrusion into or assumption,
of legislative power.
Section 32 of Republic Act No. 4670 provides for an indeterminable period of imprisonment,
with neither a minimum nor a maximum duration having been set by the legislative authority.
The courts are thus given a wide latitude of discretion to fix the term of imprisonment, without
even the benefit of any sufficient standard, such that the duration thereof may range, in the
words of respondent judge, from one minute to the life span of the accused. Irremissibly, this
cannot be allowed. It vests in the courts a power and a duty essentially legislative in nature and
which, as applied to this case, does violence to the rules on separation of powers as well as the
non-delegability of legislative powers. This time, the preumption of constitutionality has to yield.

People v. Dacuycuy: Imprisonment, in The Discretion of The Court. (Emphasis Supplied)

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People v. Dacuycuy: Imprisonment, in The Discretion of The Court. (Emphasis Supplied)

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People v.

The disputed section of Republic Act No. 4670 provides:

 On April 4, 1975, private respondents Celestino S. Matondo, Segundino A. Caval, and

2.) WON Section 32 of said RA No. 4670 is constitutional.

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