Schneckenburger vs Moran

G.R. No. L-44896 July 31, 1936

Facts:
The petitioner was duly accredited honorary consul of Uruguay at Manila, Philippine
Islands. He was
subsequently charged in the Court of First Instance of Manila with the crime of
falsification of a private
document. He objected to the jurisdiction on the ground that both under the
Constitution of the United
States and the Constitution of the Philippines the court below had no jurisdiction
to try him. The
petitioner contend that the Court of First Instance of Manila is without
jurisdiction to try the case
filed against the him for the reason that under Article III, Section 2, of the
Constitution of the United
States, the Supreme Court of the United States has original jurisdiction in all
cases affecting ambassadors,
other public ministers, and consuls, and such jurisdiction excludes the courts of
the Philippines; and
even under the Constitution of the Philippines original jurisdiction over cases
affecting ambassadors and
such public ministers and consuls, is conferred exclusively upon the Supreme Court
of the Philippines

Issue:
Whether or not the Court of First Instance of Manila has the jurisdiction to try
the petitioner and no
the Supreme Court as provided in the Constitution

Ruling:
The Constitution of The United States provided that the Supreme Court shall include
all cases
affecting ambassadors, other public ministers, and consuls. In construing this
constitutional
provision, the Supreme Court of the United States held that the "original
jurisdiction thus conferred
upon the Supreme Court by the Constitution was not exclusive jurisdiction. The laws
in force in the
Philippines prior to the inauguration of the Commonwealth conferred upon the Courts
of the First
Instances original jurisdiction in all criminal cases to which a penalty of more
than six months'
imprisonment or a fine exceeding $100(Act No. 136, Sec. 65) might be imposde. Such
jurisdiction
included the trial of criminal actions brought against consuls for, as we have
already indicated,consuls,
not being entiteled to the privileges and immunities of ambassadors or ministers,
are subject to the
laws and regulatations of the country where they reside. The Court of First
Instance has jurisdiction
to try the petitioner, and the petition was denied.