Isip v People

Isip v. People of the Philippines Facts: Petitioner Manuel Isip was charged with Estafa beforethe RTC of Cavite City, after he allegedly received fromcomplainant, Atty. Jose, a sevencarat diamond men’s ring valued at P200,000.00, for the purpose of selling thesame on commission basis and to deliver the proceeds of the sale thereof or return the same if not sold. Petitionerdenied receiving the jewelry and failed to return the ringor 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 Violationof BP 22 (Bouncing Checks Law) after she issued checks inpayment for assorted pieces of jewelry she received fromAtty. Jose which were subsequently dishonoured forinsufficiency of funds. The complainant alleged that theforegoing transactions happened at his ancestral housein Cavite while he was on leave of absence from theBureau of Customs. In defense, petitioner averred thatthe RTC had no jurisdiction over the case because he andhis 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 saidallegations. Upon appeal to the CA, Marietta Isip diedbefore any decision could have been promulgatedthereby 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 offenseimputed to petitioner and for which he was convicted. Held: Yes. The complainant had sufficiently shown that thetransaction took place in his home in Cavite. Since it hasbeen 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 competentevidence that the transaction happened in Manila due tothe following reasons:a. Even if petitioner lives in Manila and the issuedchecks were drawn against banks in Manila orMakati, it still does not prove that the transactionsdid not happen in Cavite. Distance will not preventany person from going to a distant place where hecan 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 aregenerally conclusive and binding upon this Court.

The concept of venue of actions in criminal cases, unlikein civil cases, is jurisdictional. The place where the crimewas committed determines not only the venue of theaction but is an essential element of jurisdiction. It is afundamental rule that for jurisdiction to be acquired bycourts in criminal cases:a. The offense should have been committed; orb. Any one of its essential ingredients should’ve takenplace within the court’s territorial jurisdiction.Territorial jurisdiction in criminal cases is the territorywhere the court has jurisdiction to take cognizance or totry the offense allegedly committed therein. Thus, itcannot take jurisdiction over a person charged with anoffense committed outside that territory. Furthermore,the jurisdiction of a court over the criminal case isdetermined by the allegations in the complaint orinformation. Once it is so shown, the court may validlytake cognizance of the case. However, if the evidenceadduced during the trial shows that the offense wascommitted somewhere else, the court should dismissthe action for want of jurisdiction.

Landbank of the Philippines v. Belista Facts: Spouses Ralla donated 8 parcels of lot located in Albay totheir daughter, Rene Ralla Belista, herein privaterespondent. Consequently, the 8 parcels of lot wereplaced by DAR under the coverage of the ComprehensiveAgrarian Reform Program. Belista then claimed paymentof just compensation over said agricultural lands. DAR'sevaluation of the subject farms was only at P227,582.58,while petitioner Land Bank assessed the same atP317,259.31. Believing that her lots were grosslyunderestimated, Belista filed a Petition for Valuation andPayment of Just Compensation against Landbank beforethe Regional Agrarian Reform Adjudicator (RARAD). TheRARAD issued a Decision wherein the just compensationfor the subject areas was fixed at P2,540,211.58.Aggrieved, petitioner Landbank filed an original Petitionfor Determination of Just Compensation at the the RTC.The RTC dismissed the case for failure to exhaustadministrative 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 butthe court a quo still denied its MFR. Petitioner Landbankelevated the case before the CA through a Petition forReview. The CA ruled that under the 2003 DARAB Rulesof Procedure, an appeal from the adjudicator's resolutionshould be filed before the Department of AgrarianReform Adjudication Board (DARAB) and not before the RTC and that petitioner's filing of the case before the RTC without first seeking the intervention of the DARAB isviolative of the doctrine of nonexhaustion of administrative remedies. Petitioner filed a MFR, but thesame 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 canresort to the RTC sitting as a Special Agrarian Court. Held: No. Petitioner properly filed the petition before the RTCand, hence, the RTC erred in dismissing the case.Section 56 of RA 6657 provides that DAR is vested withprimary jurisdiction to determine and adjudicate agrarianreform matters and shall have exclusive original jurisdiction over all matters involving the implementationof agrarian reform, except those falling under theexclusive jurisdiction of the Department of Agricultureand the Department of Environment and NaturalResources. Section 57 of RA 6657 provides that theSpecial 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 andexclusive jurisdiction are all petitions for determinationof just compensation to landowners and prosecution of all criminal offenses under RA 6657, which are withinthe original and exclusive jurisdiction of the RTC sittingas a Special Agrarian Court. Jurisdiction over the subjectmatter is conferred by law. Only a statute can confer jurisdiction on courts and administrative agencies whilerules of procedure cannot.