Isip v. People of the Philippines-Landbank v. Belista.docx
Criminal Procedure Isip v. People of the Philippines Facts: Petitioner Manuel Isip was charged with Estafa before the RTC of Cavite City, after he allegedly received from complainant, Atty. Jose, a seven-carat diamond men’s ring valued at P200,000.00, for the purpose of selling the same on commission basis and to deliver the proceeds of the sale thereof or return the same if not sold. Petitioner denied receiving the jewelry and failed to return the ring or proceeds of the sale even after repeated demand. On the other hand, petitioner’s wife, Marietta Isip, was indicted before the same court for 7 counts of Violation of BP 22 (Bouncing Checks Law) after she issued checks in payment for assorted pieces of jewelry she received from Atty. Jose which were subsequently dishonoured for insufficiency of funds. The complainant alleged that the foregoing transactions happened at his ancestral house in Cavite while he was on leave of absence from the Bureau of Customs. In defense, petitioner averred that the RTC had no jurisdiction over the case because he and his wife had transactions with the complainant at the latter’s residence located at Plaza Tower Condominium in Manila as both of them were also Manila residents. Despite this, the trial court found them guilty of the said allegations. Upon appeal to the CA, Marietta Isip died before any decision could have been promulgated thereby extinguishing her criminal and civil liability. However, the CA still affirmed Manuel Isip’s conviction for estafa, hence this appeal. Issue: Whether the trial court had jurisdiction over the offense imputed to petitioner and for which he was convicted. Held: Yes. The complainant had sufficiently shown that the transaction took place in his home in Cavite. Since it has been shown that venue was properly laid, it is now petitioner’s task to prove otherwise. In the instant case, petitioner failed to establish by sufficient and competent evidence that the transaction happened in Manila due to the following reasons: a. Even if petitioner lives in Manila and the issued checks were drawn against banks in Manila or Makati, it still does not prove that the transactions did not happen in Cavite. Distance will not prevent any person from going to a distant place where he can procure goods he can sell to earn a living. b. It is settled that when the RTC’s findings have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court.
The concept of venue of actions in criminal cases, unlike in civil cases, is jurisdictional. 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: a. The offense should have been committed; or b. Any one of its essential ingredients should’ve taken place within the court’s territorial jurisdiction. Territorial jurisdiction in criminal cases is the territory where the court has jurisdiction to take cognizance or to try the offense allegedly committed therein. Thus, it cannot take jurisdiction over a person charged with an offense committed outside that territory. Furthermore, 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 shows that the offense was committed somewhere else, the court should dismiss the action for want of jurisdiction. Landbank of the Philippines v. Belista Facts: Spouses Ralla donated 8 parcels of lot located in Albay to their daughter, Rene Ralla Belista, herein private respondent. Consequently, the 8 parcels of lot were placed by DAR under the coverage of the Comprehensive Agrarian Reform Program. Belista then claimed payment of just compensation over said agricultural lands. DAR's evaluation of the subject farms was only at P227,582.58, while petitioner Land Bank assessed the same at P317,259.31. Believing that her lots were grossly underestimated, Belista filed a Petition for Valuation and Payment of Just Compensation against Landbank before the Regional Agrarian Reform Adjudicator (RARAD). The RARAD issued a Decision wherein the just compensation for the subject areas was fixed at P2,540,211.58. Aggrieved, petitioner Landbank filed an original Petition for Determination of Just Compensation at the the RTC. The RTC dismissed the case for failure to exhaust administrative remedies and/or comply with Sections 5, 6, and 7, Rule XIX of the 2003 DARAB Rules of Procedure. Landbank lodged a MFR arguing that the DARAB Rules of Procedure does not apply to Special Agrarian Courts but the court a quo still denied its MFR. Petitioner Landbank elevated the case before the CA through a Petition for Review. The CA ruled that under the 2003 DARAB Rules of Procedure, an appeal from the adjudicator's resolution should be filed before the Department of Agrarian Reform Adjudication Board (DARAB) and not before the
Criminal Procedure RTC and that petitioner's filing of the case before the RTC without first seeking the intervention of the DARAB is violative of the doctrine of non-exhaustion of administrative remedies. Petitioner filed a MFR, but the same was denied, hence, this petition. Issue: Whether it is necessary that in cases involving claims for just compensation under RA 6657, the RARAD’s Decision must first be appealed to DARAB before a party can resort to the RTC sitting as a Special Agrarian Court. Held: No. Petitioner properly filed the petition before the RTC and, hence, the RTC erred in dismissing the case. Section 56 of RA 6657 provides that DAR is vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture and the Department of Environment and Natural Resources. Section 57 of RA 6657 provides that the Special Agrarian Court shall have original and exclusive jurisdiction over all petitions for: a) Determination of just compensation to landowners; b) Prosecution of all criminal offenses under this Act. Clearly, further exception to DAR's original and exclusive jurisdiction are all petitions for determination of just compensation to landowners and prosecution of all criminal offenses under RA 6657, which are within the original and exclusive jurisdiction of the RTC sitting as a Special Agrarian Court. Jurisdiction over the subject matter is conferred by law. Only a statute can confer jurisdiction on courts and administrative agencies while rules of procedure cannot.