G.R. No.

230718, September 16, 2020

PEOPLE OF THE PHILIPPINES VS. CRISANTO HAYA Y DELOS SANTOS

Facts:

Crisanto was convicted for violation of Section 5 and 11 of RA 9165. A motion for
reconsideration was filed arguing that the prosecution failed to prove his guilt and procedure
required to conduct a buy bust operation pursuant to Illegal Sale and Possession of Dangerous
Drugs was not complied. This includes the following:

(1) the seized items must be marked, inventoried, and photographed immediately after
seizure or confiscation; and
(2) the marking, physical inventory, and photographing must be done in the presence of

(a) the accused or his/her representative or counsel,

(b) an elected public official,
(c) a representative from the media and
(d) a representative from the DOJ, all of whom shall be required to sign the
copies of the inventory and be given a copy thereof

In this case, the items were alleged to have not marked immediately at the place of arrest.
Additionally, the inventory was undertaken without the presence of a representative from the
DOJ and an elected public official, it was shown that only a representative of media witnessed
the marking.

Issue:

Whether or not the presence of the enumerated witnesses in Section 21 of RA 9165 during the
marking is required for the admissibility of the evidence seized during the buy bust operation

Ruling:

General Rule: the procedure in Section 21 of RA 9165 must be complied. The presence of the
accused, elected public official, media and DOJ is required during the markings of evidence

Exception to the General Rule: There are instance where we can depart from such procedures,
the prosecution must prove that the presence of the insulting witnesses was not obtained
because of the following:

(1) their attendance was impossible because the place of arrest was a remote area;
(2) their safety during the inventory and photograph of the seized drugs was threatened
by an immediate retaliatory action of the accused or any persons acting for and in his/her
behalf;
(3) the elected officials themselves were involved in the punishable acts sought to be
apprehended;
(4) earnest efforts to secure the presence of a DOJ or media representative and an elected
public official within the period required under Article 125 of the Revised Penal Code prove
futile through no fault of the arresting officers, who face the threat of being charged with
arbitrary detention; or
(5) time constraints and urgency of the anti-drug operations, which often rely on tips of
confidential assets, prevented the law enforcers from obtaining the presence of the required
witnesses even before the offenders could escape.

However, in this case, the prosecution failed to explain why they failed to comply with the
procedure required for marking, inventory and photography. Prosecution also failed to
establish that there was an earnest effort to secure the presence of the witnesses.

Thus, the conviction of Crisanto is not correct

GR No. 216824
 Gina Villa Gomez vs People of the Philippines

Facts:

Gina was prosecuted for corruption of public officials. The RTC, after both parties presented
their evidence, dismissing the case because the Assistant City Prosecutor had no authority to
prosecute the case for the Information filed was not signed by the City Prosecutor.

The Prosecution, through the OSG, filed a petition for certiorari to annul the decision of the
RTC. They argued that there is no provision in the ROC which restricts the signing of the
Information only to the city or provincial prosecutor to the exclusion of their assistants. The CA
rendered the Decision granting the petition of the Prosecution.

Gina challenges the decision of the CA insisting that the RTC was correct in dismissing the case
because there is a jurisdictional infirmity (lack of authority) and may be question at any stage of
the proceedings. The OSG on its part argued that the court cannot quashed the information
especially when trial was already doe and the parties had already completed the presentation of
their evidence.

Issue:

Whether or not the RTC acted in grave abuse of discretion when it dismissed the case on the
ground that the signatory of the information was only the assistant city prosecutor and not the
city prosecution

Ruling:

Yes,

Rule 117 of the RTC Section 3: Grounds: The accused may move to quash the complaint or
information on any of the following grounds:

xxx

d. that the officer who filed the information had no authority to do so

Section 9 of the same ruled provides:

The failure of the accused to assert any ground of a motion to quash before he pleads to
the complaint or information, either because he did not file a motion to quash or failed to
allege the same in said motion, shall be deemed a waiver of any objections except those based
on the grounds provided for in paragraphs (a), (b), (g), and (i) of section 3 of this Rule.

Furthermore, there is no law that requires that an Information filed must be signed by the
provincial, city, or chief state prosecutor in order for trial courts to acquire jurisdiction over a
criminal case. The ruling in Villa vs. Ibanez which states that the absence of the signature of a
city, provincial, or chief state prosecutor results in a jurisdictional defect is unconstitutional.
Only a law may confer jurisdiction to courts of law. Once jurisdiction is conferred, the
jurisdiction does not cease simply because the prosecutor who filed the Information had no
authority. At worst, the absence of authority on the part of the prosecutor who filed the
Information only gives rise to a question on his standing in court.

G.R. No. 182926, June 22, 2015

ANA LOU B. NAVAJA vs HON. MANUEL A. DE CASTRO
Facts:

DKT Philippines filed a complaint for falsification of private document against Navaja before
the MCTC. It was alleged that while Navaja was in Bohol she falsified the receipt and making to
appear that she incurred meal expenses of P1,810 instead of the P810.

Navaja filed a Motion to Quash on the ground that the MCTC had no jurisdiction due to
improper venue because the essential elements of the crime of falsification of private document
was not occurred in Jagna, Bohol. This motion was denied by MCTC and set the case for
arraignment. Navaja thereafter filed a motion for reconsideration before the RTC, but it was as
well denied because there are sufficient evidence indicating that the falsification took in Jagna,
Bohol.

Navaja elevated the case to CA but also denied, hence this petition

Issue:

Whether or not MCTC of Jagna Bohol has jurisdiction over the case filed against Navaja

Ruling:

Yes, MCTC Jagna Bohol has jurisdiction over the complaint of falsification of private document
filed against Navaja.

In the case of Foz vs People, the court explained that venue in criminal cases is an essential
element of jurisdiction. The 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. This is pursuant to Section 15(a), Rule 110 of the 2000
Revised Rules of Criminal Procedure.

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.

In this case, base on the evidence and testimonies presented, Navaja actually falsified the receipt
in Jagna Bohol upon receiving it and thereafter claim for reimbursement with DKT. Thus it is
clear that the falsification of private document falls within the territorial jurisdiction of the
MCTC of Jagna Bohol.

G.R. No. 214647, March 04, 2020

EDWIN TALABIS vs PEOPLE OF THE PHILIPPINES
Facts:

Leonora filed a complaint against Talabis for violation of Revised Forestry Code of the
Philippines. It was alleged that Talabis cut pine trees without the necessary permits to the land
owned by Leonora’s daughter.

The RTC found Talabis guilty of the crime charged which the CA affirmed. Hence a petition
was filed before the SC arguing the RTC has no jurisdiction since the offended party under PD
705 is the government, the complaint against Talabis should have been filed by a DENR official,
and not by Leonora who is merely private individuals.

Issue:

Whether or not the trial court acquired jurisdiction over the case even it was filed by a private
individual and not by the DENR officer

Ruling:

Yes, Section 80 of PD 705 contemplates situations where acts in violation of the law were
committed in the presence of forest officers, or when reports or complaints of violations of PD
705, albeit not committed in their presence, are brought to the attention of forest officers by
other forest officers or any deputized officers or officials.

In this case, it was not a forest officer who reported the tree-cutting activities of Talabis, but
Leonora, a private individual, who had a land dispute with Talabis over the land covering the
cutting site.

Hence, Section 80, particularly the second category thereof, will not apply in the instant case.

G.R. Nos. 236308-09, February 17, 2020

EFREN M. CANLAS vs PEOPLE OF THE PHILIPPINES

Facts:
With regard to the construction of Makati City Hall Parking Building, two information were
filed for violation of Section 3(e) of RA 3019 or Anti-Graft and Corrupt Practices Act alleging
that the Canlas and other officials of Makati City conspired to grant Hilmarc the contract by
giving unwarranted benefits and advantage which causes undue injury to the Government.

Canlas filed a motion to quash the information arguing that Section 3(e) of RA 3019 explicitly
applies only to public officers and not to private individual. This motion was denied by the
Sandiganbayan. The People argues that a private individual, when acting with public officials,
may be indicted and held liable under Section 3(e) of RA 3019.

Hence this petition

Issue:

Whether or not private individual can be held liable under RA 3019

Ruling:

Yes, private individual can be still liable under RA 3019

In the case of PCGG vs Ombudsman the court enumerates the elements of Section 3(e) of RA
3019 namely:

(i) that the accused must be a public officer discharging administrative, judicial, or
official functions, or a private individual acting in conspiracy with such public officers;

(ii) that he acted with manifest partiality, evident bad faith, or inexcusable negligence;
and

(iii) that his action caused any undue injury to any patty, including the government, or
giving any private party unwarranted benefits, advantage, or preference in the
discharge of his functions.

In this case, all elements have ben sustained. Moreover, by the very nature of the transaction
involved in this case, which is a government procurement and by petitioner's indispensable acts
towards the consummation of the offense, he should be indicted together with the accused
public officials for violation of Section 3(e) of RA 3019

G.R. No. 162059, January 22, 2008

Hanna Eunice Serana v. Sandiganbayan

FACTS:
Petitioner Hannah Eunice D. Serana was a senior student of the UP-Cebu. She was appointed
by then President Joseph Estrada as a student regent of UP. Petitioner, with her siblings and
relatives, registered with the SEC the Office of the Student Regent Foundation, Inc. (OSRFI).
One of the projects of the OSRFI was the renovation of the Vinzons Hall Annex. President
Estrada gave 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. The
renovation of Vinzons Hall Annex failed to materialize.

The succeeding student regent, Kristine Clare Bugayong, and Christine Jill De Guzman,
Secretary General of the KASAMA sa U.P., a system-wide alliance of student councils within
the state university, consequently filed a complaint for Malversation of Public Funds and
Property with the Office of the Ombudsman. The Ombudsman found probable cause to indict
petitioner and her brother Jade Ian D. Serana for estafa and filed the case to the Sandiganbayan.
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. The Sandiganbayan denied petitioner’s motion for lack of merit. Petitioner filed a
motion for reconsideration but was denied with finality.

Hence, this case.

ISSUE:

(1) Whether or not the Sandiganbayan has jurisdiction over an estafa case?
(2) Whether or not the petitioner is a public officer?

RULING:

1. Yes. Section 4(B) of P.D. No. 1606 which defines the jurisdiction of the Sandiganbayan reads:
“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.”

In the case at bar, there’s no plausible or sensible reason to exclude estafa as one of the offenses
included in Section 4(b) of P.D. No. 1606. Plainly, estafa is one of those other felonies.
Therefore, Sandiganbayan has jurisdiction over an estafa case.

2.Yes. Section 4(A)(1)(g) of P.D. No. 1606 explictly vested the Sandiganbayan with jurisdiction
over Presidents, directors or trustees, or managers of government-owned or controlled
corporations, state universities or educational institutions or foundations.
In the case at bar, Petitioner falls under this category. As the Sandiganbayan pointed out, the
Board of Regent performs functions similar to those of a board of trustees of a non-stock
corporation. By express mandate of law, petitioner is, indeed, a public officer as contemplated
by P.D. No. 1606.
Therefore, Petitioner is a public officer.
 G.R. No. 122068 July 8, 1998
JUANITO MANZANO vs HON. REDENTOR VALERA and VILMA A. BOBILA

Facts:
Bobila filed a complaint for libel against Manzano, when the latter indicated in the blotter a
defamatory statement against Bobila. Hon. Valera recognized that RTC had jurisdiction over the
case, thus, he forwarded the records to Prosecutors Office. However, the Prosecutor returned
the records and requested to transmit it to the MTC.

Upon acceptance of MTC, Manzano filed a Motion to Dismiss, invoking that MTC has no
jurisdiction over the offense charged following the decision in the case of Jalandoni vs Endaya
wherein the court ruled that the RTC has the exclusive original jurisdiction over libel cases.
However, Hon. Valera denied the motion and held that the controlling law is RA 7691 which
expands the jurisdiction of MTC because it is the later enactment.

Hence, this petition.

Issue:

Whether or not the MTC has the jurisdiction in libel cases

Ruling:

No, MTC has no jurisdiction over libel cases.

In the case of People vs MTC the court ruled that pursuant to Article 360 of RPC the jurisdiction
over libel cases is lodged with the Courts of First Instance (now Regional Trial Courts)

Furthermore, a later enactment like RA 7691 does not automatically override an existing law,
because it is a well-settled principle of construction that, in case of conflict between a general
law and a special law, the latter must prevail regardless of the dates of their enactment—
jurisdiction conferred by a special law on the RTC must therefore prevail over that granted by a
general law on the MTC.

In this case, Judge Valera committed an error in ordering that the criminal case for libel be tried
in the MTC.

G.R. No. 233174, January 23, 2019

Raul Francis Cabral v. Chris Bracamonte

FACTS:

Cabral instituted a complaint for estafa against Bracamonte in Parañaque City. Finding
probable cause, the prosecutor filed with the RTC of Parañaque City an Information.
After arraignment and presentation of prosecution evidence, Bracamonte moved to quash the
Information contending that the venue was improperly laid in Parañaque City, because the
postdated check was delivered and dishonored in Makati City. Thus, the prosecution failed to
show how the supposed elements of the crime charged were committed in Parañaque City. In
contrast, Cabral maintained that the averments in the complaint and Information are controlling
to determine jurisdiction. Since the complaint affidavit alleged that negotiations on the MOA
were conducted in a warehouse in Parañaque City where Cabral was convinced to sell his
shares in the two corporations, then the RTC of Parañaque City properly had jurisdiction.

the RTC denied the Motion to Quash explaining that it has jurisdiction over the case because
Bracamonte employed fraudulent acts against Cabral in Parañaque City prior to the issuance of
the postdated check.

The CA reversed the Decision of the RTC. The CA ruled that jurisdiction solely lies in Makati
City where all the elements of the crime occurred.

Hence, this case.

ISSUE:

Whether or not the trial court is devoid of jurisdiction to try the criminal case against
bracamonte as venue was improperly laid thus dismissing the information.

RULING:

Yes, "territorial jurisdiction in criminal cases is the territory where the court has jurisdiction to
take cognizance of or to try the offense allegedly committed therein by the accused. In all
criminal prosecutions, the action shall be instituted and tried in the court of the municipality or
territory wherein the offense was committed or where any one of the essential ingredients took
place.

In this case, the crime allegedly committed by Bracamonte is estafa under Article 315,
paragraph 2(d) of the Revised Penal Code. in this form of estafa, it is not the non-payment of a
debt which is made. punishable, but the criminal fraud or deceit in the issuance of a check.

it was merely stated in the Information, and alleged by Cabral in his complaint affidavit, that
the crime of estafa was committed in Parañaque City because it was there that he was
convinced to sell the subject shares of stock. Apart from said allegation, however, he did not
present any evidence, testimonial or documentary, that would support or corroborate the
assertion. Equally guilty of the same failure to substantiate is the trial court which relied merely
on Cabral's complaint affidavit in connecting the alleged offense within its territorial
jurisdiction, the pieces of evidence on record point only to one place: Makati City.

Therefore, the trial court is devoid of jurisdiction to try the criminal case against bracamonte as
venue was improperly laid.
 G.R. No. 212448 January 11, 2018
AAA vs BBB

Facts:

An information for violation of RA 9262 was filed by AAA against his husband BBB, who was a
permanent resident in Singapore. It was alleged that BBB sent them a little to no financial
support. Furthermore, when AAA visited BBB in Singapore, they had a violent altercation
because AAA discovered that BBB had an affair with Singaporean woman which causes AAA
mental and emotional anguish.

BBB filed a motion to quash the information, which the RTC granted and held that they don’t
have jurisdiction over the offense charged considering that the acts complained of had occurred
in Singapore which is outside their territorial limits.

Aggrieved with the decision of the RTC, AAA filed an instant petition direct to the SC because
of pure question of law. AAA argues that mental and emotional anguish is an essential element
of the offense charged against BBB, which is experienced by her wherever she goes, and not
only in Singapore where the extra-marital affair takes place; thus, the RTC of Pasig City where
she resides can take cognizance of the case.

Issue:

Whether or not the Philippine court may exercise jurisdiction over cases involving the violation
of RA 9262 which marital infidelity committed outside the country

Ruling:

Yes, the Philippine court has jurisdiction over cases involving the violation of RA 9262 which
marital infidelity committed outside the country

As a general rule, as explained in the case of Trenas vs People the court ruled that the place
where the crime was committed determines not only the venue of the action but is an
essential element of jurisdiction. 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 should have taken place within the territorial jurisdiction of the court.

However, exception to the general rule is that when the crime is transitory or continuing;
meaning that some acts material and essential thereto and requisite in their consummation
occur in one municipality or territory, while some occur in another. In such cases, the court
wherein any of the crime’s essential and material acts have been committed maintains
jurisdiction to try the case; it being understood that the first court taking cognizance of the same
excludes the other. Thus, a person charged with a continuing or transitory crime may be validly
tried in any municipality or territory where the offense was in part committed.

In this case, the court ruled that even if the alleged extra-marital affair causing the offended
wife mental and emotional anguish is committed abroad, the RTC may exercise the jurisdiction
over the case since AAA was resident thereof where she suffered anguish being a material
element of the offense