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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 dept. 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.

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