Case Digest: G.R. No.

149453 (April 1, 2003)

Title: People of the Philippines vs. Panfilo M. Lacson

Court: Supreme Court of the Philippines

Date: April 1, 2003

Facts:

The case involves multiple murder charges against respondent Panfilo M. Lacson and his co-accused for the deaths
of eleven individuals, allegedly members of the Kuratong Baleleng Gang. The initial criminal cases (Nos. Q-99-
81679 to Q-99-81689) were dismissed provisionally by Judge Wenceslao Agnir, Jr. on March 29, 1999, due to lack
of probable cause, following a motion filed by Lacson for a judicial determination of probable cause. This dismissal
occurred without proper notice to all offended parties, raising questions about the validity of the dismissal under
Section 8, Rule 117 of the Revised Rules of Criminal Procedure.

Issues:

Whether the provisional dismissal had the express consent of the accused (Lacson).

Whether the dismissal can be revived after the two-year time bar under Section 8, Rule 117.

Whether the new rule should be applied retroactively.

Ruling:

Consent to Dismissal: The Court found that the provisional dismissal was not made with the express consent of
Lacson. The respondent did not file a motion for dismissal but sought a judicial determination of probable cause,
indicating he did not agree to a provisional dismissal.

Revival of Dismissed Cases: The Court determined that the requirements of Section 8, Rule 117 were not met. Since
the dismissal lacked express consent and proper notice to all offended parties, the cases could be revived without
being barred by the time limit stated in the rule. The State could pursue the charges irrespective of the two-year
limit.

Retroactive Application: The Court ultimately ruled that Section 8, Rule 117 is procedural and can be applied
retroactively. It emphasized that the intent of the rule is to protect the rights of the accused and ensure timely
prosecution by the State.

FACTS:

The petitioner, People of the Philippines (petitioner) seeks the reversal of the Order dated May 18, 2007, issued by
the Regional Trial Court (RTC), Branch 30 of Surigao City, which was dismissed for lack of jurisdiction over the
subject matter of the criminal case for estafa. Veneranda is the wife of the late Dionisio Paler, Sr. who is the
registered owner of a parcel of irrigated riceland, containing an area of more than four (4) hectares, situated in
Barangay Mabini (Roxas), Mainit, Surigao del Norte. One (1) hectare of this riceland was cultivated by the
respondents as agricultural tenants for more than ten (10) years, with an agreed lease rental of twelve and one half
(12 1⁄2) cavans of palay, at 45 kilos per cavan, per harvest. The respondents allegedly failed to pay the rent since
1997 which amounts to ₱80,000.00.

Initially, Veneranda brought the matter before the Department of Agrarian Reform (DAR) Office in Mainit, Surigao
del Norte, but no amicable settlement was reached by the parties. Thus, Veneranda filed a criminal complaint for
estafa against the respondents.
In an Order dated May 18, 2007, the RTC dismissed the criminal case stating that the Department of Agrarian
Reform Adjudication Board (DARAB) has jurisdiction over the matter.

ISSUE:

Whether the RTC has jurisdiction over the crime of estafa as alleged by the petitioner.

RULING:

YES. The Regional Trial Court of Surigao City has jurisdiction over the crime of estafa as alleged by the petitioner.
The Supreme Court reiterated the doctrines relative to the respective jurisdictions of RTC and DARAB:

The three important requisites in order that a court may acquire criminal jurisdiction are (1) the court must have
jurisdiction over the subject matter; (2) the court must have jurisdiction over the territory where the offense was
committed; and (3) the court must have jurisdiction over the person of the accused.

For the first requisite: The RTC has jurisdiction over the subject matter because the law confers on it the power to
hear and decide cases involving estafa.

For the second requisite: The RTC also has jurisdiction over the offense charged since the crime was committed
within its territorial jurisdiction.

For the third requisite: The RTC likewise acquired jurisdiction over the persons of the respondents because they
voluntarily submitted to the RTC's authority.

Thus, where the court has jurisdiction over the subject matter and over the person of the accused, and the crime was
committed within its territorial jurisdiction, the court necessarily exercises jurisdiction over all issues that the law
requires the court to resolve. Therefore, the Supreme Court found that the RTC erroneously concluded that it lacks
jurisdiction over the subject matter on the premise that the case before it is purely an agrarian dispute.

However, the Court found it not necessary to remand the case to the trial court for further proceedings, as it would
only further delay the resolution of the case. It then declared that respondents cannot be held liable for estafa for
their failure to pay the rental on the agricultural land subject of the leasehold.

Case Digest: Crisologo v. People of the Philippines

G.R. No. L-6277, February 26, 1954

Facts: Petitioner Juan D. Crisologo, a military officer, was charged with treason in the People's Court in 1946.
Before the case proceeded, he was indicted in a military court in 1947 under the Articles of War for treason and
another offense (causing civilian deaths). The military court acquitted him of the treason charges but convicted him
of the second offense, sentencing him to life imprisonment. After the People's Court was abolished, the treason case
was transferred to the Court of First Instance of Zamboanga. Crisologo moved to quash the information, claiming
double jeopardy due to the military court proceedings. The motion was denied, leading to this petition for certiorari
and prohibition.

Issue: Does the military court's decision bar further prosecution for the same offense in civil courts?

Held: Yes. The Supreme Court held that the military court's conviction, even on a different charge within the same
overall offense of treason, bars further prosecution in civil courts. The Court reasoned that:

1. Both courts derived their power from the same sovereignty (the Philippines).
2. The military court had jurisdiction over Crisologo and the offense. While the civil court information
included additional overt acts not mentioned in the military indictment, these were part of the continuous
offense of treason, not separate offenses.
 3. The People's Court hadn't obtained jurisdiction over Crisologo's person before the military court's
proceedings began. Mere priority in filing an information is insufficient; jurisdiction over the person is also
required.

The Court cited precedents establishing that a conviction or acquittal in a court with concurrent jurisdiction bars
further prosecution in another court of the same sovereignty for the same offense. The additional overt acts in the
civil court's information did not constitute a new offense.

Disposition: The petition was granted, and the treason case in the Court of First Instance of Zamboanga was
dismissed.

Cruz v. CA, G.R. No. 123340, August 29,2002.

FACTS:

•The petitioner is charged with the crime of "Estafa thru Falsification of Public Document"

•Petitioner executed before a Notary Public in the City of Manila an Affidavit of Self-Adjudication of a parcel of
land stating that she was the sole surviving heir of the registered owner when in fact she knew there were other
surviving heirs.

•The offended party did not reserve the right to file a separate civil action hence the civil action was deemed
instituted in the criminal case.

•The trial court acquitted the petitioner on the ground of reasonable doubt and ordered to return to the surviving
heirs of the parcel of land located in Bulacan.

•The trial court denied the petitioner’s motion for reconsideration.

•Court of Appeals also denied due course to the petition and dismissed the case for being insufficient in substance.

ISSUE: WHETHER THE COURT OF APPEALS ERRED IN FINDING THAT THE REGIONAL TRIAL COURT
OF MANILA HAD JURISDICTION TO RENDER JUDGMENT ON THE CIVIL ASPECT OF CRIMINAL CASE
NO. 87-57743 FOR FALSIFICATION OF PUBLIC DOCUMENT, INVOLVING A PROPERTY LOCATED IN
BULACAN? NO.

RULING: No, the CA did not err in finding that the RTC of Manila had jurisdiction to render judgment on a civil
case involving a property in Bulacan.

The Supreme Court upholds the ruling of the Court of Appeals which states that:

Being a civil liability arising from the offense charged, the governing law is the Rules of Criminal Procedure, not the
civil procedure rules which pertain to civil action arising from the initiatory pleading that gives rise to the suit.

There are three important requisites which must be present before a court can acquire criminal jurisdiction. First, the
court must have jurisdiction over the subject matter. Second, the court must have jurisdiction over the territory
where the offense was committed. Third, the court must have jurisdiction over the person of the accused.

In the instant case, the trial court had jurisdiction over the subject matter as the law has conferred on the court the
power to hear and decide cases involving estafa through falsification of a public document. The trial court also had
jurisdiction over the offense charged since the crime was committed within its territorial jurisdiction. The trial court
also acquired jurisdiction over the person of accused-petitioner because she voluntarily submitted to the court’s
authority.

Where the court has jurisdiction over the subject matter and over the person of the accused, and the crime was
committed within its territorial jurisdiction, the court necessarily exercises jurisdiction over all issues that the law
requires the court to resolve. One of the issues in a criminal case is the civil liability of the accused arising from the
crime. Article 100 of the Revised Penal Code provides that "[E]very person criminally liable for a felony is also
civilly liable." Article 104 of the same Code states that "civil liability x x x includes restitution."

The action for recovery of civil liability is deemed instituted in the criminal action unless reserved by the offended
party. In the instant case, the offended party did not reserve the civil action and the civil action was deemed
instituted in the criminal action. Although the trial court acquitted petitioner of the crime charged, the acquittal,
grounded on reasonable doubt, did not extinguish the civil liability.20 Thus, the Manila trial court had jurisdiction to
decide the civil aspect of the instant case - ordering restitution even if the parcel of land is located in Bulacan.

Foz, Jr. v. People, G.R. No. 167764, October 9, 2009

FACTS

1. Petitioners were charged with the crime of libel before the RTC of Iloilo.

2. The accused, a columnist and an Editor-Publisher of Panay News , a daily publication in the City of Iloilo,
published an article, entitled, “Meet Dr. Portigo, Company Physician” exposing Dr. Portigo to public hatred and
contempt.

3. In the said article, a wife of an employee where Dr. Portigo was a company doctor, died due to his wrong
diagnosis of Lita Payunan.

4. Dr. Portigo argued that the said article was entirely false and malicious, highly libelous, offensive and
deregatory to the good name, character and reputation of Dr. Portigo.

ISSUE/S: Whether the RTC of Iloilo City, Branch 23 has jurisdiction over the offense of libel.

RULING: No. The RTC of Iloilo has no jurisdiction.

The SC held that Dr. Portigo is a private individual at the time of the publication of the alleged libelous article, the
venue of the libel case may be in the province or city where the libelous article was printed and first published, or in
the province where Dr. Portigo actually resided at the time of the commission of the offense.

Settled is the rule that jurisdiction of a court over a criminal case is determined by the allegations of the complaint or
information, and the offense must have been committed or any one of its essential ingredients took place within the
territorial jurisdiction of the court. Considering that the Information failed to allege the venue requirements for a
libel case under Article 360, the Court finds that the RTC of Iloilo City had no jurisdiction to hear this case.

Thus, its decision convicting petitioners of the crime of libel should be set aside for want of jurisdiction without
prejudice to its filing with the court of competent jurisdiction.

Navaja v. de castro, g.r. no. 182926, june 22,2015.

FACTS: The instant case arose from a Complaint-Affidavit filed by the private respondent against the petitioner,
alleging that while she was still its Regional Sales Manager, she falsified a receipt making it appear that she incurred
meal expenses in the amount of P1,810, instead of the actual amount of P810, at Garden Cafe, Jagna, Bohol, and
claimed reimbursement for it.

This allegation has caused Navaja to be charged with falsification of a private document in the Municipal Circuit
Trial Court (MCTC) of Jagna-Garcia-Hernandez, Bohol, under Criminal Case No. 2904.

Navaja contested the MCTC’s jurisdiction over the criminal case, arguing that none of the elements of the offense
occurred in Jagna, Bohol, thereby making the venue improper. Her Motion to Quash and subsequent Motion for
Reconsideration were both denied by the MCTC. Navaja escalated the matter to the Regional Trial Court (RTC) of
Loay, Bohol, Branch 50, which also ruled against her, holding that evidence indicated the falsification occurred in
Jagna.

Navaja then appealed to the Court of Appeals (CA) which affirmed the RTC’s decision.

Hence, this petition.

ISSUE/S: Whether or not the MCTC of Jagna-Garcia-Hernandez, Bohol has jurisdiction over the crime of
falsification of private documents.

DECISION: Yes, the MCTC of Jagna-Garcia-Hernandez, Bohol has jurisdiction over the crime of falsification
of private documents.

Venue in criminal cases is an essential element of jurisdiction. This principle was explained by the Court in Foz, Jr.
v. People, thus:

xxx the jurisdiction of a court over the criminal case is determined by the allegations in the complaint or
information. And once it is so shown, the court may validly take cognizance of the case. However, if the evidence
adduced during the trial show that the offense was committed somewhere else, the court should dismiss the action
for want of jurisdiction.

In determining the venue where the criminal action is to be instituted and the court which has jurisdiction over it,
Section 15(a), Rule 110 of the 2000 Revised Rules of Criminal Procedure provides:

(a) Subject to existing laws, the criminal action shall be instituted and tried in the court or municipality or territory
where the offense was committed or where any of its essential ingredients occurred.

Section 10, Rule 110 of the 2000 Revised Rules of Criminal Procedure pertinently states:

Place of commission of the offense. – The complaint or information is sufficient if it can be understood from its
allegations that the offense was committed or some of its essential ingredients occurred at some place within the
jurisdiction of the court, unless the particular place where it was committed constitutes an essential element of the
offense charged or is necessary for its identification.

In Union Bank of the Philippines v. People, the Court said that both provisions categorically place the venue and
jurisdiction over criminal cases not only in the court where the offense was committed, but also where any of its
essential ingredients took place. In other words, the venue of action and of jurisdiction are deemed sufficiently
alleged where the Information states that the offense was committed or some of its essential ingredients occurred at
a place within the territorial jurisdiction of the court.

Brocka vs. Enrile. G.R. No. 69863-65 December 10, 1990

DOCTRINE: Indeed, the general rule is that criminal prosecution may not be restrained or stayed by injunction,
preliminary or final. There are however exceptions, among which are:
a. To afford adequate protection to the constitutional rights of the accused
b. When necessary for the orderly administration of justice or to avoid oppression or multiplicity of actions
c. When there is a pre-judicial question which is sub judice
d. When the acts of the officer are without or in excess of authority
e. Where the prosecution is under an invalid law, ordinance or regulation
f. When double jeopardy is clearly apparent
g. Where the court has no jurisdiction over the offense
h. Where it is a case of persecution rather than prosecution
i. Where the charges are manifestly false and motivated by the lust for vengeance
j. When there is clearly no prima facie case against the accused and a motion to quash on that ground has been
denied
Where there is manifest bad faith that accompanies the filing of criminal charges, as in the instant case where
Brocka, Et. Al. were barred from enjoying provisional release until such time that charges were filed, and where a
sham preliminary investigation was hastily conducted, charges that are filed as a result should lawfully be enjoined.

FACTS: Petitioners Lino Brocka, Benjamin Cervantes, Cosme Garcia, and Rodolfo Santos were arrested on
January 28, 1985, following the forceful dispersal of a demonstration supporting a jeepney strike organized by the
Alliance of Concerned Transport Organizations (ACTO). They were initially charged with illegal assembly. While
some co-accused were released on bail, Brocka et al., charged as leaders, were initially denied bail. Despite a court
order for their release on February 9th, they remained detained, with respondents citing a Preventive Detention
Action (PDA) issued on January 28th. Crucially, neither the original nor a certified copy of this PDA was ever
presented to the petitioners. On February 11th, without prior notice to their counsel, Brocka et al. were charged with
inciting to sedition, a charge that appeared to be based on substantially the same speech and actions as the illegal
assembly charges. The petitioners alleged that the inquest was a sham, conducted in haste and without proper
consideration of their rights, and that the inciting to sedition charges were filed to circumvent their right to bail.
Their provisional release was ultimately ordered by President Ferdinand Marcos on February 14th, rendering the
habeas corpus aspect of the petition moot.

ISSUE: Whether or not criminal prosecution for inciting to sedition, based on the same act as an earlier charge, may
lawfully be enjoined.

RULING: Yes. The Court ruled in favor of Brocka, Et. Al. and enjoin their criminal prosecution for the second
offense of inciting to sedition. Indeed, the general rule is that criminal prosecution may not be restrained or stayed
by injunction, preliminary or final. There are however exceptions, among which are:

a. To afford adequate protection to the constitutional rights of the accused

b. When necessary for the orderly administration of justice or to avoid oppression or multiplicity of actions
c. When there is a pre-judicial question which is sub judice
d. When the acts of the officer are without or in excess of authority
e. Where the prosecution is under an invalid law, ordinance or regulation
f. When double jeopardy is clearly apparent
g. Where the court has no jurisdiction over the offense
h. Where it is a case of persecution rather than prosecution
i. Where the charges are manifestly false and motivated by the lust for vengeance
j. When there is clearly no prima facie case against the accused and a motion to quash on that ground has been
denied

Where there is manifest bad faith that accompanies the filing of criminal charges, as in the instant case where
Brocka, Et. Al. were barred from enjoying provisional release until such time that charges were filed, and where a
sham preliminary investigation was hastily conducted, charges that are filed as a result should lawfully be enjoined.

Isip v. People, G.R. No. 170298, June 26, 2007

Neri
Topic: Venue in Criminal Cases is Jurisdictional

DOCTRINE:
The concept of venue of actions in criminal cases, unlike in civil cases, is jurisdictional—for jurisdiction to be
acquired by courts in criminal cases, the offense should have been committed or any one of its essential ingredients
should have taken place within the territorial jurisdiction of the court.

FACTS: Manuel S. Isip was charged with Estafa for misappropriating a seven-carat diamond ring valued at
₱200,000.00, which he had received from complainant Atty. Leonardo Jose for the purpose of selling on a
commission basis. The ring was to be returned or the proceeds of its sale were to be handed over to Jose by a
specified deadline, but Isip failed to do so. Marietta M. Isip, his wife, was also charged with multiple counts of
violation of Batas Pambansa Blg. 22 for issuing dishonored checks as payment for jewelry.

The couple was initially acquitted of several charges but was convicted in Criminal Case No. 136-84 for Estafa
related to the misappropriated ring. The Regional Trial Court (RTC) of Cavite City found that the transaction
occurred in Cavite City, despite the defense’s argument that the transactions were conducted in Manila. Isip
appealed the ruling, arguing that the RTC lacked jurisdiction over the case, as the transaction did not occur in Cavite
City, but in Manila. The Court of Appeals affirmed the RTC's ruling but modified the sentence.

Facts: Manuel Isip was convicted of Estafa by the Regional Trial Court (RTC) of Cavite City for failing to return a
7-carat diamond ring he received from Leonardo Jose on commission. Isip argued that the transaction occurred in
Manila, not Cavite, and that he had already settled his obligations with Jose through property transfers. The Court of
Appeals affirmed the conviction.

ISSUE: Whether the trial court had jurisdiction over the offense of Estafa committed by petitioner.

RULING: Yes. The Supreme Court ruled that the trial court had jurisdiction over the case, affirming the findings of
the RTC and the Court of Appeals. The Court emphasized that venue in criminal cases is jurisdictional, and the
place where the crime was committed determines the proper court to hear the case. Since the complainant showed
that the transaction occurred in Cavite City and not in Manila, the RTC of Cavite City properly had jurisdiction over
the case. The petitioner’s argument that the transaction occurred in Manila lacked sufficient proof and was
unpersuasive.

Union Bank of the Philippines v. People of the Philippines, G.R. No. 192565, February 28, 2012

FACTS: Desi Tomas was charged in court for perjury under Article 183 of the Revised Penal Code (RPC) for
making a false narration in a Certificate against Forum Shopping.

The accusation stemmed from petitioner Union Bank’s two (2) complaints for sum of money with prayer for a writ
of replevin against the spouses Eddie and Eliza Tamondong and a John Doe. The first complaint, docketed as Civil
Case No. 98-0717, was filed before the RTC, Branch 109, Pasay City on April 13, 1998. The second complaint,
docketed as Civil Case No. 342-000, was filed on March 15, 2000 and raffled to the MeTC, Branch 47, Pasay City.
Both complaints showed that Tomas executed and signed the Certification against Forum Shopping. Accordingly,
she was charged of deliberately violating Article 183 of the RPC by falsely declaring under oath in the Certificate
against Forum Shopping in the second complaint that she did not commence any other action or proceeding
involving the same issue in another tribunal or agency.

Tomas filed a Motion to Quash, citing two grounds. First, she argued that the venue was improperly laid since it is
the Pasay City court (where the Certificate against Forum Shopping was submitted and used) and not the MeTC-
Makati City (where the Certificate against Forum Shopping was subscribed) that has jurisdiction over the perjury
case. Second, she argued that the facts charged do not constitute an offense because: (a) the third element of perjury
– the willful and deliberate assertion of falsehood – was not alleged with particularity without specifying what the
other action or proceeding commenced involving the same issues in another tribunal or agency; (b) there was no
other action or proceeding pending in another court when the second complaint was filed; and (c) she was charged
with perjury by giving false testimony while the allegations in the Information make out perjury by making a false
affidavit.

ISSUE/S: Whether the proper venue of perjury under Article 183 of the RPC should be in Makati City,
where the Certificate against Forum Shopping was notarized, or Pasay City, where the Certification was presented to
the trial court.
DECISION: We deny the petition and hold that the MeTC-Makati City is the proper venue and the proper court
to take cognizance of the perjury case against the petitioners.

Venue of Action and Criminal Jurisdiction

Venue is an essential element of jurisdiction in criminal cases. It determines not only the place where the criminal
action is to be instituted, but also the court that has the jurisdiction to try and hear the case. The reason for this rule
is two-fold. First, the jurisdiction of trial courts is limited to well-defined territories such that a trial court can only
hear and try cases involving crimes committed within its territorial jurisdiction. Second, laying the venue in the
locus criminis (place of the crime) is grounded on the necessity and justice of having an accused on trial in the
municipality of the province where witnesses and other facilities for his defense are available.

Unlike in civil cases, a finding of improper venue in criminal cases carries jurisdictional consequences. In
determining the venue where the criminal action is to be instituted and the court which has jurisdiction over it,
Section 15(a), Rule 110 of the 2000 Revised Rules of Criminal Procedure provides:

(a) Subject to existing laws, the criminal action shall be instituted and tried in the court or municipality or territory
where the offense was committed or where any of its essential ingredients occurred. [emphasis ours]

The above provision should be read in light of Section 10, Rule 110 of the 2000 Revised Rules of Criminal
Procedure which states:

Place of commission of the offense. – The complaint or information is sufficient if it can be understood from its
allegations that the offense was committed or some of its essential ingredients occurred at some place within the
jurisdiction of the court, unless the particular place where it was committed constitutes an essential element of the
offense charged or is necessary for its identification.

Both provisions categorically place the venue and jurisdiction over criminal cases not only in the court where the
offense was committed, but also where any of its essential ingredients took place. In other words, the venue of
action and of jurisdiction are deemed sufficiently alleged where the Information states that the offense was
committed or some of its essential ingredients occurred at a place within the territorial jurisdiction of the court.

In the present case, the Certification against Forum Shopping was made integral parts of two complaints for sum of
money with prayer for a writ of replevin against the respondent spouses Eddie Tamondong and Eliza B. Tamondong,
who, in turn, filed a complaint-affidavit against Tomas for violation of Article 183 of the RPC. As alleged in the
Information that followed, the criminal act charged was for the execution by Tomas of an affidavit that contained a
falsity.

Based on these considerations, we hold that our ruling in Sy Tiong is more in accord with Article 183 of the RPC
and Section 15(a), Rule 110 of the 2000 Revised Rules of Criminal Procedure. To reiterate for the guidance of the
Bar and the Bench, the crime of perjury committed through the making of a false affidavit under Article 183 of the
RPC is committed at the time the affiant subscribes and swears to his or her affidavit since it is at that time that all
the elements of the crime of perjury are executed. When the crime is committed through false testimony under oath
in a proceeding that is neither criminal nor civil, venue is at the place where the testimony under oath is given. If in
lieu of or as supplement to the actual testimony made in a proceeding that is neither criminal nor civil, a written
sworn statement is submitted, venue may either be at the place where the sworn statement is submitted or where the
oath was taken as the taking of the oath and the submission are both material ingredients of the crime committed. In
all cases, determination of venue shall be based on the acts alleged in the Information to be constitutive of the crime
committed.

FACTS: In December 1999, Margarita Alocilja (Margarita) wanted to buy a house-and-lot in Iloilo City covered by
TCT No. 109266. It was then mortgaged with Maybank. The bank manager Joselito Palma recommended the
appellant Hector Treñas (Hector) to private complainant Elizabeth, who was an employee and niece of Margarita,
for advice regarding the transfer of the title in the latter’s name. Hector informed Elizabeth that for the titling of the
property in the name of her aunt Margarita, the expenses would amount to Php 150,000

Thereafter, Elizabeth gave P150,000.00 to Hector who issued a corresponding receipt dated December 22, 1999 and
prepared [a] Deed of Sale with Assumption of Mortgage. Subsequently, Hector gave Elizabeth Revenue Official
Receipt Nos. 00084370 for P96,000.00 and 00084369 for P24,000.00. However, when she consulted with the BIR,
she was informed that the receipts were fake. When confronted, Hector admitted to her that the receipts were fake
and that he used the P120,000.00 for his other transactions. Elizabeth demanded the return of the money.

To settle his accounts, appellant Hector issued in favor of Elizabeth a Bank of Commerce check No. 0042856 dated
November 10, 2000 in the amount of P120,000.00. When the check was deposited with the PCIBank, Makati
Branch, the same was dishonored for the reason that the account was closed.

On October 29, 2001, the City Prosecutor filed an Information for Estafa before the RTC of Makati City. Hector
pleaded “Not Guilty” on April 26, 2002, but due to health and other reasons, he could not attend pre-trial and trial
proceedings. On January 8, 2007, the RTC found Hector guilty and sentenced him to 10 years and 1 day of prision
mayor to 17 years and 4 months of reclusion temporal, also ordering him to indemnify Elizabeth.

ISSUE: WON the RTC of Makati City lack jurisdiction over the estafa case since the evidence suggested that the
essential elements of the crime did not occur in Makati City

RULING: Yes, the Regional Trial Court (RTC) of Makati City lacked jurisdiction over the estafa case because the
evidence did not sufficiently prove that the essential elements of the crime occurred within its territorial jurisdiction.

The overarching consideration in this case is the principle that, in criminal cases, venue is jurisdictional. A court
cannot exercise jurisdiction over a person charged with an offense committed outside its limited territory.

In this case, the prosecution failed to show that the offense of estafa under Section 1, paragraph (b) of Article 315 of
the RPC was committed within the jurisdiction of the RTC of Makati City.

That the offense was committed in Makati City was alleged in the information as follows:

That on or about the 23rd day of December, 1999, in the City of Makati, Metro Manila, Philippines and within the
jurisdiction of this Honorable Court, the above-named accused, received in trust from ELIZABETH LUCIAJA the
amount of P150,000.00

Aside from the lone allegation in the Information, no other evidence was presented by the prosecution to prove that
the offense or any of its elements was committed in Makati City.

Although the prosecution alleged that the check issued by petitioner was dishonored in a bank in Makati, such
dishonor is not an element of the offense of estafa under Article 315, par. 1 (b) of the RPC.

Indeed, other than the lone allegation in the information, there is nothing in the prosecution evidence which even
mentions that any of the elements of the offense were committed in Makati. The rule is settled that an objection may
be raised based on the ground that the court lacks jurisdiction over the offense charged, or it may be considered
motu proprio by the court at any stage of the proceedings or on appeal. Moreover, jurisdiction over the subject
matter in a criminal case cannot be conferred upon the court by the accused, by express waiver or otherwise. That
jurisdiction is conferredby the sovereign authority that organized the court and is given only by law in the manner
and form prescribed by law.
It has been consistently held by this Court that it is unfair to require a defendant or accused to undergo the ordeal
and expense of a trial if the court has no jurisdiction over the subject matter or offense or it is not the court of proper
venue. Section 15 (a) of Rule 110 of the Revised Rules on Criminal Procedure of 2000 provides that "[s]ubject to
existing laws, the criminal action shall be instituted and tried in the court of the municipality or territory where the
offense was committed or where any of its essential ingredients occurred." This fundamental principle is to ensure
that the defendant is not compelled to move to, and appear in, a different court from that of the province where the
crime was committed as it would cause him great inconvenience in looking for his witnesses and other evidence in
another place. This principle echoes more strongly in this case, where, due to distance constraints, coupled with his
advanced age and failing health, petitioner was unable to present his defense in the charges against him.

The Petition is GRANTED. The Decision dated 9 July 2010 and the Resolution dated 4 January 2011 issued by the
Court of Appeals in CA-G.R. CR No. 32177 are SET ASIDE on the ground of lack of jurisdiction on the part of the
Regional Trial Court, Branch 137, Makati City. Criminal Case No. 01-2409 is DISMISSED without prejudice.

Case Name: AAA v. BBB, G.R. No. 192565, February 28, 2012

Facts: The case involves a petition by AAA against BBB concerning charges
of psychological violence under Republic Act No. 9262 (Anti-Violence Against
Women and their Children Act). AAA claimed that BBB's marital infidelity
caused her mental anguish, even though the alleged affair took place outside
the Philippines. The Regional Trial Court (RTC) dismissed AAA's petition for
certiorari, asserting it did not have jurisdiction since the acts occurred
abroad.

Issue: Can Philippine courts exercise jurisdiction over an offense of

psychological violence under R.A. No. 9262 when the marital infidelity
occurred outside the country?

Held: Yes, the Supreme Court ruled that Philippine courts can exercise
jurisdiction over such cases, even if the acts causing psychological violence
occurred abroad. The Court emphasized that the essential element of the
offense is the mental or emotional anguish suffered by the victim, which can
occur regardless of where the infidelity took place. The ruling clarified that
the venue for such cases is where the victim resides, allowing the RTC of
Pasig City to have jurisdiction since AAA and their children lived there.

Disposition: The petition was granted, and the RTC's previous resolutions
were set aside, reinstating the information against BBB in Criminal Case No.
146468.

Mondejar v. Buban, A.M. No. MTJ-01-1349, July 12, 2001

Facts: Bernadette Mondejar filed a complaint against Judge Marino S. Buban for gross ignorance of the law,
partiality, serious irregularity, and grave misconduct related to Criminal Case No. 98-07-CR-133. She alleged that
the judge issued a "hold departure order" against her without adhering to Supreme Court Circular No. 39-97, which
restricts such orders to criminal cases under the jurisdiction of Regional Trial Courts. Mondejar also claimed she
was not given a chance to be heard before the order was issued. In response, Judge Buban admitted his error, stating
he was unaware of the circular and later lifted the order.
Issue: Did Judge Buban violate the law by issuing the hold departure order in a case outside his jurisdiction?

Held: Yes, the Supreme Court found that Judge Buban erred in issuing the hold departure order because it was not
within his authority as a judge of a first-level court. The Court emphasized that judges must maintain professional
competence and stay informed about legal developments.

Disposition: Judge Marino S. Buban was reprimanded and warned that future violations would result in more severe
penalties.

LBP vs Belista G.R. No. 164631 June 26, 2009

FACTS:The case involves a dispute over the just compensation for eight parcels of agricultural land located in
Ligao, Albay, which were donated by spouses Pablo Ralla and Carmen Munoz Ralla to their daughter, Rene Ralla
Belista (the respondent). These lands were placed under the coverage of the Comprehensive Agrarian Reform
Program (CARP) by the Department of Agrarian Reform (DAR). The DAR evaluated the lands and determined the
just compensation to be P227,582.58, while the Land Bank of the Philippines (LBP) assessed it at P317,259.31.

Dissatisfied with the DAR's valuation, Belista filed a Petition for Valuation and Payment of Just Compensation
against LBP before the DARAB-Regional Adjudicator for Region V (RARAD-V) on November 11, 2002. On July
7, 2003, RARAD-V issued a decision preliminarily fixing the just compensation at P2,896,408.91. After both parties
filed motions for reconsideration, the RARAD-V modified its decision on October 8, 2003, reducing the
compensation to P2,540,211.58.

Aggrieved by this modification, LBP filed a Petition for Determination of Just Compensation with the Regional
Trial Court (RTC) on October 28, 2003. The RTC dismissed the case motu proprio on November 12, 2003, citing the
failure to exhaust administrative remedies as per the 2003 DARAB Rules of Procedure. LBP's motion for
reconsideration was denied, prompting the bank to elevate the matter to the Court of Appeals.

ISSUE/S: Whether it is necessary that in cases involving claims for just compensation under Republic Act
No. 6657 that the decision of the adjudicator must first be appealed to the DARAB before a party can resort to the
RTC sitting as Special Agrarian Court (SAC).

DECISION: No. The Court emphasized that the jurisdiction to determine just compensation for landowners
under Republic Act No. 6657 (RA 6657) is vested in the RTC sitting as a Special Agrarian Court (SAC). The Court
clarified that while the DAR has primary jurisdiction to initially determine just compensation, this determination is
subject to judicial review.

Although Section 5, Rule XIX of the 2003 DARAB Rules of Procedure provides that the land valuation cases
decided by the adjudicator are now appealable to the Board, such rule could not change the clear import of Section
57 of RA No. 6657 that the original and exclusive jurisdiction to determine just compensation is in the RTC. Thus,
Section 57 authorizes direct resort to the SAC in cases involving petitions for the determination of just
compensation. In accordance with the said Section 57, petitioner properly filed the petition before the RTC and,
hence, the RTC erred in dismissing the case.

People v. Sandiganbayan, August 25, 2009, G.R. No. 167304

FACTS:Victoria Amante was a member of the Sangguniang Panlungsod of Toledo City, Province of Cebu. On
January 14, 1994, she had a cash advance amounting to P71,095.00 under a disbursement voucher to pay for the
seminar expenses of the Committee on Health and Environmental Protection, in which she headed. As of December
19, 1995, no liquidation was made. On December 22, 1995, Manolo V. Tulibao, the Toledo City Auditor, gave a
letter to Amante demanding her to settle her unliquidated cash advance. On May 17, 1996, the Commission on Audit
filed an investigation report to the Office of the Deputy Ombudsman for Visayas (OMB-Visayas), and further
recommended that respondent be investigated whether charges could be filed against her under P.D. 1445, also
known as The Auditing Code of the Philippines. On September 30, 1999, OMB-Visayas issued a Resolution
recommending the filing of an Information for Malversation of Public Funds against Amante. On May 21, 2004, the
Office of the Special Prosecutor (OSP) filed an Information with the Sandiganbayan accusing Amante of violating
Sec. 89 of P.D. No. 1445.

The case was raffled to the Third Division of the Sandiganbayan. Amante contends that the Sandiganbayan had no
jurisdiction over the said criminal case because Amante had a position with Salary Grade 26, whereas Sec. 4 of R.A.
No. 8249 provides that the Sandiganbayan shall have original jurisdiction in cases wherein the accused holds a
position with Salary Grade 27 and higher.

On February 28, 2005, the Sandiganbayan dismissed the case against Amante for lack of jurisdiction.

ISSUE/S: Whether or not a Sangguninang Panlungsod member who had a position with Salary Grade 26,
who was charged with violation of The Auditing Code of the Philippines, falls within the jurisdiction of the
Sandiganbayan.

DECISION: Yes, the Sandiganbayan has jurisdiction over the case of Amante.

Violation of The Auditing Code of the Philippines is under the Section 4(b) of R.A. 8249 which specifies that “b.
Other offenses or felonies whether simple or complexed with other crimes committed by the public officials and
employees mentioned in subsection a of this section in relation to their office.”

Amante’s offense is committed in relation to her office as the offense is “intimately connected” with the office of
Amante and was perpetrated while she was in the performance of her public function.

Public officials, (such as Amante), with below Salary Grade 27, still fall within the Sandiganbayan jurisdiction.
Provided that, they hold the positions stated under Sec. 4(a) of R.A. 8249, which includes being a member of the
Sangguniang Panlungsod.

Sec. 4. Jurisdiction. -- The Sandiganbayan shall exercise original jurisdiction in all cases involving:
A. Violations of Republic Act No. 3019, as amended, otherwise known as the Anti-Graft and Corrupt Practices Act,
Republic Act No. 1379, and Chapter II, Section 2, Title VII of the Revised Penal Code, where one or more of the
principal accused are officials occupying the following positions in the government, whether in a permanent, acting
or interim capacity, at the time of the commission of the offense:
(1) Officials of the executive branch occupying the positions of regional director and higher, otherwise classified as
grade "27" and higher, of the Compensation and Position Classification Act of 1989 (Republic Act No. 6758),
specifically including:
(a) Provincial governors, vice-governors, members of the sangguniang panlalawigan and provincial treasurers,
assessors, engineers, and other city department heads;
(b) City mayors, vice-mayors, members of the sangguniang panlungsod, city treasurers, assessors, engineers, and
other city department heads.
(c) Officials of the diplomatic service occupying the position of consul and higher;
(d) Philippine army and air force colonels, naval captains, and all officers of higher rank;
(e) PNP chief superintendent and PNP officers of higher rank;
(f) City and provincial prosecutors and their assistants, and officials and prosecutors in the Office of the
Ombudsman and Special Prosecutor;
(g) Presidents, directors or trustees, or managers of government-owned or controlled corporations, state universities
or educational institutions or foundations;
(2) Members of Congress and officials thereof classified as Grade "27" and up under the Compensation and Position
Classification Act of 1989;
(3) Members of the judiciary without prejudice to the provisions of the Constitution;
(4) Chairmen and members of Constitutional Commissions, without prejudice to the provisions of the Constitution;
and
(5) All other national and local officials classified as Grade "27" and higher under the Compensation and Position
Classification Act of 1989.
B. Other offenses or felonies, whether simple or complexed with other crimes committed by the public officials and
employees mentioned in subsection (a) of this section in relation to their office.
C. Civil and criminal cases filed pursuant to and in connection with Executive Order Nos. 1, 2, 14 and 14-A.

Serrana v. Sandiganbayan, January 22, 2008, G.R. 162059

FACTS:Petitioner Hannah Eunice D. Serana was a senior student of the University of the Philippines-Cebu. A
student of a state university is known as a government scholar. She was appointed by then President Joseph Estrada
and has discussed with President Estrada the renovation of Vinzons Hall Annex in UP Diliman. President Estrada
gave Fifteen Million Pesos (P15,000,000.00) to the OSRFI as financial assistance for the proposed renovation. The
source of the funds, according to the information, was the Office of the President. However, the renovation of
Vinzons Hall Annex failed to materialize.

Petitioner moved to quash the information. She claimed that the Sandiganbayan does not have any jurisdiction over
the offense charged or over her person, in her capacity as UP student regent. Petitioner claimed that Republic Act
(R.A.) No. 3019, as amended by R.A. No. 8249, enumerates the crimes or offenses over which the Sandiganbayan
has jurisdiction. It has no jurisdiction over the crime of estafa. It only has jurisdiction over crimes covered by Title
VII, Chapter II, Section 2 (Crimes Committed by Public Officers), Book II of the Revised Penal Code (RPC). Estafa
falling under Title X, Chapter VI (Crimes Against Property), Book II of the RPC is not within the Sandiganbayan’s
jurisdiction.

The Ombudsman opposed the motion. It disputed the petitioner's interpretation of the law. Section 4(b) of
Presidential Decree (P.D.) No. 1606 clearly contains the catch -all phrase "in relation to office," thus, the
Sandiganbayan has jurisdiction over the charges against petitioner.

ISSUE/S: Whether or not Sandiganbayan has jurisdiction over Estafa.

DECISION: The petition is DENIED for lack of merit.

Relying on Section 4 of P.D. No. 1606, petitioner contends that estafa is not among those crimes cognizable by the
Sandiganbayan. The Court has noted that in hoisting this argument, petitioner isolated the first paragraph of Section
4 of P.D. No. 1606, without regard to the succeeding paragraphs of the said provision.

Every section, provision or clause of the statute must be expounded by reference to each other in order to arrive at
the effect contemplated by the legislature. The intention of the legislator must be ascertained from the whole text of
the law and every part of the act is to be taken into view. In other words, petitioner’s interpretation lies in direct
opposition to the rule that a statute must be interpreted as a whole under the principle that the best interpreter of a
statute is the statute itself. Optima statuti interpretatrix est ipsum statutum.

Section 4(B) of P.D. No. 1606 reads:

B. Other offenses or felonies whether simple or complexed with other crimes committed by the public officials and
employees mentioned in subsection a of this section in relation to their office.
Evidently, the Sandiganbayan has jurisdiction over other felonies committed by public officials in relation to their
office. The Court sees no plausible or sensible reason to exclude estafa as one of the offenses included in Section
4(bB) of P.D. No. 1606. Plainly, estafa is one of those other felonies. The jurisdiction is simply subject to the twin
requirements that (a) the offense is committed by public officials and employees mentioned in Section 4(A) of P.D.
No. 1606, as amended, and that (b) the offense is committed in relation to their office.