Case Name/Brief Facts Doctrine: Jurisdiction Cases Week 1 - Doctrines

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de Jesus/2B - CRIMPRO JURISDICTION CASE DOCTRINES 9/16/17, 1:09 PM

JURISDICTION CASES
WEEK 1 - DOCTRINES

Note: WalaNOTA BENE:


ng facts, READ
guys. THE CASE
Pahabol lang DIGESTS/FULL
ito. Handwritten TEXT
notesFIRST BEFORE
kasi ako noongUSING
tinatryTHIS.
ko pang mag full
text HAHAHA. THIS TABLE IS ONLY FOR PURPOSES OF RECALL. :)

CASE NAME/BRIEF FACTS DOCTRINE


Antiporda v Garchitorena In order for the Court to have authority to dispose of the case, it
- kidnapping of Elmer Ramos. should have Jurisdiction (JD) over the subject & parties to the
- amended info: alleged that Mayor case.
Antiporda took advantage of his
official position when he ordered HELD: SB has no JD over the subject matter.
brgy. officials to idnap HOWEVER, petitioner is estopped from questioning the same
- MQ filed to quash amended info. since in his MR he challenged the JD of the RTC by stating that
— alleged that the same was the offense was office-related.
voluntary submission
- Pet (petitioner) questions JD of A party cannot invoke the JD of the court to secure
SB since the orig info did not allege affirmative relief and afterwards repudiate the same JD. SB,
taking advantage of official info. in this case, acquired JD because of estoppel.

Note: SB had JD over the person of the accused since the


motion to quash was tantamount to voluntary submission
People v Sola HELD:
- 7 informations for murder were (1) ON BAIL- There was failure on the requirement for the
found based on the bodies found prosecution to be heard in a case where the accused is charged
under the cane field after digging with a capital offense prior grant of bail.
during the course of a search - cancellation of bail bonds proper — prosecution cannot be
conducted by the authorities deprived of procedural due process. Hence, the judgment
pursuant to a search warrant. granting bail is void.
- W/o giving the prosecution to
prove the evidence of guilt is strong (2) ON CHANGE OF VENUE - proper
—> granted them bail - to compel trial at a place where the witnesses do not have
- change of venue petition by liberty to reveal what they know is a mockery of the judicial
witnesses - granted system
- in case of doubt - resolve in favor of change of venue
People v Dapitan HELD: If an accused has been heard in a court of competent
- information for robbery w/ JD, and proceeded against the orderly process of law, and only
homicide punished after inquiry or investigation, upon notice to him with
- case where mother left her son opportunity to be heard, and a judgment awarded within the
alone in their house. she found her authority of a constitutional law —> Due Process (DP) is served.
son dead upon return (scattered
brain) - Robbery w/homicide - single, indivisible penalty (Art. 63, RPC
- mitigating circumstance of applies). Not inhumane penalty —> RPC is constitutional
voluntary surrender
- accused argues that the
imposition of the penalty of
R e c l u s i o n Te m p o r a l w a s
tantamount to deprivation of life,
liberty, property (LLP), that the
same was inhuman, etc.

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de Jesus/2B - CRIMPRO JURISDICTION CASE DOCTRINES 9/16/17, 1:09 PM

NOTA BENE: READ THE CASE DIGESTS/FULL TEXT FIRST BEFORE USING THIS.
THIS TABLE IS ONLY FOR PURPOSES OF RECALL. :)
Alonte v Sevillano HELD: Due process was not served.
- info filed against Mayor Alonte and - Even if the right to confront and cross-examine may be waived,
Concepcion (accomplice) for raping the waiver should be voluntary and made knowingly (mere
a girl (gave her water to make her silence =/= waiver)
dizzy) - Deviations from the regular course of trial were committed.
- Victim filed a petition for change of Petitioners have not been directed to present evidence to prove
venue, but subsequently executed their defenses nor have been scheduled to do the same. No
an affidavit of desistance. admission was made by the accused so as to warrant change in
- warrants were issued — issue is the order of trial.
hearing on the voluntariness of the
affidavit of desistance only — There can be no shortcut to due process.
contended that the same was a
denial of due process
Cruz v CA HELD: Yes. The law has JD over the subject matter as the law
- falsification of public document re has conferred on the court the power to hear and decide cases
affidavit of self-adjudication that involving estafa through falsification of a public document.
petitioner was the only surviving - TC also had JD over the offense charged since the crime was
heir to a parcel of land, when in fact committed within its territorial JD.
she was not. - TC also had JD over the person of the accused.
- acquitted in criminal case, but civil
case reserved by the offended —> Hence, TC exercises JD over all issues that the law requires
party it to resolve, including civil liability. Hence, the court is vested
- issue is whether or not the RTC of with the power to order the restitution to the offended party of
Manila has JD over the parcel of the real party even if the same is located in another place.
land located in Bulacan.
People v Go HELD: Private persons, in conspiracy with Public Officers may
- violation of RA 3019 for having be liable for violating RA 3019.
entered into a disadvantageous
contract to the prejudice of the - Death of Enrile does not man that the allegation of conspiracy
government (NAIA maintenance) between them can no longer be proved since death of a co-
- Go’s co-accused Arturo Enrile accused does not negate the existence of a crime.
already died - The law does not strictly require the private person to be
- Go argues that SB has no JD over indicted with the public officer since he may be indicted alone
him because he was not a public (also, conspiracy was present)
officer and that his co-accused who
was the public officer was already - Moreover, bail was posted — Voluntary submission to SB’s JD
dead. - Moreover, SB has JD over violations of RA 3019, including
private persons who violate the same.
Cojuangco v SB HELD: In order to avoid the submission of his body to the JD of
- coco levy funds, violation of RA the court, he must raise the question of the court’s JD over his
3019 person at the very earliest opportunity.
- posted bail. warrant cancelled. - Giving or posting bail by the accused is tantamount to
- issue is consequent to the nullity voluntary submission.
of the warrant, w/n SB may still - Hence, Cojuangco already waived his rights to object to the
exercise JD over Cojuangco and same by appearing and giving bond. By posting bail, petitioner
proceed with the trial. cannot claim exemption from being being subject to the
jurisdiction of the SB.

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de Jesus/2B - CRIMPRO JURISDICTION CASE DOCTRINES 9/16/17, 1:09 PM

NOTA BENE: READ THE CASE DIGESTS/FULL TEXT FIRST BEFORE USING THIS.
THIS TABLE IS ONLY FOR PURPOSES OF RECALL. :)
Miranda v Tuliao HELD: JD over the person is accomplished either by pleading or
- burn cadavers were discovered in by filing bail. As regards to the latter, since the same is intended
Isabela. to obtain affirmative relief, the same cannot be posted before
- infos for murder were filed. custody of the accused has been acquired either by arrest or
- motion to complete PI was filed voluntary surrender.
- Judge cancelled warrants for lack
of Probable cause (PC) CUSTODY OF LAW JD OVER THE PERSON
- issue is whether or not RTC - required before the court - waived when applies for any
already acquired JD when they filed can act upon the bail pleading seeking affirmative
for motion to complete PI and application but not required relief, except in cases of
motion to recall/quash warrants of for adjudication of other special appearance questiong
arrest. reliefs where the mere the JD of the court.
application constitutes a
defense of lack of JD

*Hence, an accused can invoke the court processes even


though there is neither JD over the person nor custody of the
law. However, custody of law is required in granting bail.
David v Agbay (See Miranda v Tuliao)
- naturalized Canadian citizen,
applied for Miscellaneous Lease HELD: Custody of Law is not required for other affirmative reliefs
Application before the CENRO aside from bail.
- falsification of public documents - MTC erred in dismissing the same since the filing of the motion
was filed on the ground of his of petitioner was tantamount to voluntary submission.
declaration as a Filipino in his
application.
- motion for re-determination of PC
was filed in the MTC. — MTC
dismissed for lack of JD
Alva v CA HELD: RTC has JD — when he appeared during arraignment
- estafa, defrauded visa application and plead not guilty to the charge notwithstanding the fact that
- issue is whether or not RTC has he jumped bail.
JD in light of the bail filed.
CA has no JD - no custody of the law since he was a fugitive,
and not deprived of his liberty. Custody of the law is literally
custody over the body of the accused. It includes, but is not
limited to, detention.
HELD: There was grave abuse of discretion when the Judge
dismissed the case on lack of JD on such basis

- JD is determined by the allegations in the info and not by what


was found in the trial, much less than the judge’s personal
People v Ocaya
appraisal of the affidavits without having the parties and their
- physical injuries
witnesses heard and receipt of other evidence
- judgment rendered based on
medical certificate — Light SPI so
- the mere fact that the evidence presented at trial would
RTC has no JD
indicate a much lesser offense does not deprive the court of its
JD which was VESTED BY THE ALLEGATIONS IN THE INFO.

- once JD attaches, subsequent events will not operate to oust


JD already attached.

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