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    University of The Philippines College of Law: Lopez v. City

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    Maribel Nicole Lopez
    The Supreme Court held that the City Fiscal of Angeles City did not have jurisdiction to hear the case against the petitioners. The crime of falsifying a private document was committed beyond Angeles City's territorial limits, as the reinvestigation details showed. As a general rule, a lower court's denial of a motion to quash will not be annulled by a writ of certiorari or prohibition. However, in this case the Supreme Court declared the offense was beyond the lower court's jurisdiction and prohibited further proceedings.

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    University of The Philippines College of Law: Lopez v. City

    Uploaded by

    Maribel Nicole Lopez
    388 views2 pages
    The Supreme Court held that the City Fiscal of Angeles City did not have jurisdiction to hear the case against the petitioners. The crime of falsifying a private document was committed beyond Angeles City's territorial limits, as the reinvestigation details showed. As a general rule, a lower court's denial of a motion to quash will not be annulled by a writ of certiorari or prohibition. However, in this case the Supreme Court declared the offense was beyond the lower court's jurisdiction and prohibited further proceedings.

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    1 - Lopez v City

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    The Supreme Court held that the City Fiscal of Angeles City did not have jurisdiction to hear the case against the petitioners. The crime of falsifying a private document was committed beyond Angeles City's territorial limits, as the reinvestigation details showed. As a general rule, a lower court's denial of a motion to quash will not be annulled by a writ of certiorari or prohibition. However, in this case the Supreme Court declared the offense was beyond the lower court's jurisdiction and prohibited further proceedings.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    388 views2 pages

    University of The Philippines College of Law: Lopez v. City

    Uploaded by

    Maribel Nicole Lopez
    The Supreme Court held that the City Fiscal of Angeles City did not have jurisdiction to hear the case against the petitioners. The crime of falsifying a private document was committed beyond Angeles City's territorial limits, as the reinvestigation details showed. As a general rule, a lower court's denial of a motion to quash will not be annulled by a writ of certiorari or prohibition. However, in this case the Supreme Court declared the offense was beyond the lower court's jurisdiction and prohibited further proceedings.

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    © All Rights Reserved
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    of 2

    University of the Philippines College of Law

    JEBJ, 1-D

    Topic Venue
    Case No. G.R. No. L-25795/ October 29, 1966
    Case Name Lopez v. City
    Ponente Justice Dizon

    RELEVANT FACTS
     On Februrary 1964, Roy P. Villasor who was administrator of the estates of the Spouses Mejia along
    with Angelina Lopez, Aurora Villasor and other heirs entered into a contract with Trinidad Lazatin for the
    development and subdivision of three parcels of land belonging to the intestate estate who then
    transferred his rights to the Terra Development Corporation. A few months later they filed for the
    recission of said contract for alleged gross and willful violations of its terms.

     Lazatin et. al. then filed a complaint with the City Fiscal of Angeles a complaint for the falsification of a
    private documents. Following a preliminary investigation, the Fiscal then filed an information against the
    Villasors for having pretended in the contract that Aurora Villasor was the guardian of the minors
    George Mejia and Angelina Lopez when she wasn’t.

     The Villasors filed a petition that caused a reinvestigation by the Fiscal to give them an opportunity to
    present exculpatory evidence and after reinvestigation moved for a dismissal of the case claiming the
    fiscal had not authority citing that the document was signed outside Angeles’ territorial limits. The
    resolution of the motion to dismiss was delayed and in the meantime the Court set the criminal case for
    arraignment but this was postponed several times by the defendants.

     On November 26, 1965 the Villasors filed a motion to dismiss citing that the City Fiscal had no
    jurisdiction. The Fiscal filed an opposition thereto and on February 3, 1966 the respondent Judge denied
    the motion to dismiss and reset the arraignment for March 5, 1966.

     Petitioners then filed a Petition for Certiorari and Prohibition to elevate the case before the Supreme
    Court.

    ISSUE
    W/N The Fiscal has the Jurisdiction to hear and try the case?

    RATIO DECIDENDI

    Issue Ratio
    W/N The Fiscal has the YES
    Jurisdiction to hear and try
    the case? 1. The Supreme Court held that the crime of falsification of private
    documents is consummated when the document is actually falsified with the
    intent of a third person. The Court noted that the part of the record
    containing details of the reinvestigation in connection with the Motion to
    University of the Philippines College of Law
    JEBJ, 1-D

    Quash showed that offense was committed beyond the jurisdiction of


    Angeles City.

    2. The Court also held that as a general rule, a court of equity will not issue a
    writ of certiorari to annul an order of a lower court denying a motion to
    quash or a writ of prohibition to prevent said court from proceeding with a
    case after such denial, due to the rule that the defendant should plead not
    guilty and then go to trial.

    RULING

    WHEREFORE, … judgment is hereby rendered declaring that the offense charged in the information filed in
    Criminal Case No. C-2268 of the City Court of Angeles City is not within the jurisdiction of said court and that,
    therefore, said court is hereby restrained and prohibited from further proceedings therein. Costs against the private
    respondents.

    SEPARATE OPINIONS

    NOTES

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