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CASANAS v. PEOPLE (CrimProc Digest)
CASANAS v. PEOPLE (CrimProc Digest)
PEOPLE
G.R. No. 223833 December 11, 2017
Criminal Procedure: Court jurisdiction may be raised as an issue at any time in the proceedings;
A court has no jurisdiction over criminal offenses committed outside its limited territorial jurisdiction
FACTS:
1. In this petition for review on certiorari, is assailing both the Decision dated July 28, 2015 and the Resolution
dated January 11, 2016 of the Court of Appeals (CA) affirming the Decision dated May 15, 2013 of the
Regional Trial Court of Valenzuela City, Branch 269 (RTC-Valenzuela) finding petitioner Joshua Casanas y
Cabantac, a.k.a. Joshua Geronimo y Lopez (Casanas) guilty beyond reasonable doubt of the crime of
Carnapping, defined and penalized under Section 2 of Republic Act No. (RA) 6539, otherwise known as the
"Anti-Carnapping Act of 1972".
2. An Information was filed before the RTC-Valenzuela charging Casanas of the crime of Carnapping, the
accusatory portion of which reads:
That on or about August 12, 2012, in Valenzuela City and within the jurisdiction of this
Honorable Court, the above-named accused, with intent to gain, did then and there willfully,
unlawfully and feloniously take and carry away with him one (1) Racal motorcycle with plate
number 7539IJ without the consent of its owner CHRISTOPHER CALDERON y DORIGON, to the
damage and prejudice of the said complainant.
3. The RTC-Valenzuela found Casanas guilty beyond reasonable, holding that the prosecution had
established all the elements of the crime charged, considering that:
(a) Calderon allowed petitioner to drive the subject motorcycle, which was then attached to a sidecar;
(b) Casanas did not return the subject motorcycle within the agreed period; and
(c) Casanas continued to use the same for his personal use, thereby exhibiting his intent to gain.
In this regard, the RTC-Valenzuela ruled that while Casanas's possession of the subject motorcycle was
lawful in the beginning, such possession became unlawful when he failed to return the same to Calderon in
accordance with their agreement.
4. The CA affirmed the RTC-Valenzuela ruling in toto. Aside from upholding the RTC-Valenzuela's findings,
the CA likewise pointed out that initially, Casanas borrowed a tricycle from Calderon; but when he was
apprehended, only the subject motorcycle without the sidecar was recovered from him. The CA ruled that
such removal of the sidecar from the subject motorcycle bolsters the conclusion that Casanas indeed
intended to appropriate for himself the subject motorcycle.
(a) W/N the RTC of Valenzuela had jurisdiction over the case; and [NO]
(b) W/N the CA correctly upheld Casanas' conviction for the crime of Carnapping [NO]
HOLDING/RATIO:
1. In criminal cases, venue is jurisdictional in that a court [RTC-Valenzuela] cannot exercise jurisdiction over
a person charged with an offense committed outside its limited territory [Marilao, Bulacan]. As such, when
it becomes apparent that the crime was committed outside the territorial jurisdiction of the court, the case
must be dismissed for want of jurisdiction.
Casanas primarily argues that the RTC-Valenzuela had no jurisdiction over the case, as the alleged
carnapping happened in Marilao, Bulacan, and not in Valenzuela City, where he was arrested, charged, and
tried.
2. Citing Heirs of Fernando v. De Belen, the Court averred that "the jurisdiction of a court may be questioned
at any stage of the proceedings. Lack of jurisdiction is one of those excepted grounds where the court may
dismiss a claim or a case at any time when it appears from the pleadings or the evidence on record that any
of those grounds exists, even if they were not raised in the answer or in a motion to dismiss. So that, whenever
it appears that the court has no jurisdiction over the subject matter, the action shall be dismissed. This
defense may be interposed at any time, during appeal or even after final judgment. Such is understandable,
as this kind of jurisdiction is conferred by law and not within the courts, let alone the parties, to themselves
determine or conveniently set aside."
The RTC-Valenzuela ruling convicting Casanas of the crime charged, as well as the CA ruling upholding the
same, is null and void for lack of jurisdiction. It is well-settled that "where there is want of jurisdiction over a
subject matter, the judgment is rendered null and void. A void judgment is in legal effect no judgment, by
which no rights are divested, from which no right can be obtained, which neither binds nor bars any one, and
under which all acts performed and all claims flowing out are void. It is not a decision in contemplation of law
and, hence, it can never become executory.
It also follows that such a void judgment cannot constitute a bar to another case by reason of res
judicata.
3. The SC grants the petition of Casanas, and the Decision and the Resolution of the Court of Appeals are
SET ASIDE. The Criminal Case filed in the Regional Trial Court of Valenzuela City is DISMISSED for lack of
jurisdiction, without prejudice to its re-filing in the proper court having territorial jurisdiction over the case.