CASE DIGEST: Navaja v. De Castro; G.R. No. 182926; 22 June 2015

Navaja v. De Castro

G.R. No. 182926

22 June 2015

Peralta, J.

 

Doctrine: It is a fundamental rule that for jurisdiction to be acquired by courts in criminal cases the offense should have been committed or any one of its essential ingredients took place within the territorial jurisdiction of the court. The jurisdiction of a court over the criminal case is determined by the allegations in the complaint or information. 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.

 

Facts:

Respondent DKT Philippines filed a complaint-affidavit against petitioner Navaja alleging that she falsified receipts by making it appear that she incurred meal expenses in the amount of P1,800.00 instead P810.00 (which is the actual amount) at Garden Café, Jagna, Bohol and claimed reimbursement for it.

Subsequently, Navaja was charged with the crime of falsification of private documents with the MCTC of Jagna Bohol. Then, Navaja moved to quash and defer arraignment on the ground that none of the essential elements of the crime of falsification of private document occurred in Jagna, Bohol. Hence, MCTC had no jurisdiction to take cognizance of the case due to improper venue. Which however denied by the MCTC, considering that the accused has already submitted to the court’s jurisdiction by filing of cash bond for temporary release.

Consequently, Navaja moved for reconsideration but the same was denied. She was prompted to file a petition for certiorari before the RTC. However, RTC denied the same.

On appeal, CA dismissed the appeal and affirmed RTC’s order. Then she moved for reconsideration but was likewise denied. Hence, the instant petition for review on certiorari.

Issue:

Whether the MCTC has the jurisdiction over the falsification case against the petitioner.

Ruling: Yes. MCTC of Jagna, Bohol has jurisdiction over the falsification case against the petitioner.

It is a fundamental rule that for jurisdiction to be acquired by courts in criminal cases the offense should have been committed or any one of its essential ingredients took place within the territorial jurisdiction of the court. The jurisdiction of a court over the criminal case is determined by the allegations in the complaint or information. 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 cases of falsification of private documents, the venue is the place where the document is actually falsified, to the prejudice of or with the intent to prejudice a third person, regardless whether or not the falsified document is put to the improper or illegal use for which it was intended.

Here, the allegations in the Information and the complaint-affidavit make out a prima facie case that such crime was committed in Jagna, Bohol. In particular, the Information clearly alleged that she committed such crime thereat.

In criminal proceedings, improper venue is lack of jurisdiction because venue in criminal cases is an essential element of jurisdiction.³⁷ Unlike in a civil case where venue may be waived, this could not be done in a criminal case because it is an element of jurisdiction. Thus, one cannot be held to answer for any crime committed by him except in the jurisdiction where it was committed.

Filing of the falsification cases she allegedly committed in different jurisdictions would not result in multiplicity of actions. Such separate filing of cases is only consistent with the principles that there are as many acts of falsification as there are documents falsified and that the venue of such cases is where the document was actually falsified.