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People v. Taroy
Union Bank of the Philippines and Desi Tomas. v. People
Pangilinan vs CA
Tijam
Figueroa vs People
submitted its case for a final adjudication on the merits. It was only after an adverse decision was rendered by
the Court of Appeals that it finally woke up to raise the question of jurisdiction.
Figueroa vs People
G.R. No. 147406, July 14, 2008, J. Nachura
I. Facts
Petitioner was charged with the crime of reckless imprudence resulting in homicide. The RTC found him
guilty. In his appeal before the CA, the petitioner, for the first time, questioned RTCs jurisdiction on the case.
The CA in affirming the decision of the RTC, ruled that the principle of estoppel by laches has already
precluded the petitioner from questioning the jurisdiction of the RTCthe trial went on for 4 years with the
petitioner actively participating therein and without him ever raising the jurisdictional infirmity. The
petitioner, for his part, counters that the lack of jurisdiction of a court over the subject matter may be raised at
any time even for the first time on appeal. As undue delay is further absent herein, the principle of laches will
not be applicable. Hence, this petition.
II. Issue
Whether or not the petitioners motion to dismiss should be granted
III. Ruling
Yes. The Court held that as a general rule, the issue of jurisdiction may be raised at any stage of the
proceedings, even on appeal, and is not lost by waiver or by estoppel.
Estoppel by laches may be invoked to bar the issue of lack of jurisdiction only in cases in which the factual
milieu is analogous to that of Tijam v. Sibonghanoy. Laches should be clearly present for the Sibonghanoy
doctrine to be applicable, that is, lack of jurisdiction must have been raised so belatedly as to warrant the
presumption that the party entitled to assert it had abandoned or declined to assert it.
The petitioner is in no way estopped by laches in assailing the jurisdiction of the RTC, considering that he
raised the lack thereof in his appeal before the appellate court. At that time, no considerable period had yet
elapsed for laches to attach.
Pangilinan vs CA
G.R. No. 117363. December 17, 1999, J. Kapunan
I. Facts
The petitioner was charged with the crime of estafa before the RTC. Under the information, the accused, by
means of false pretenses and misrepresentations, introduced and misrepresented herself that she was instructed
by Mr. Rodolfo Elnar, father of Miss Luzviminda Elnar, a girl 15 years of age, to get one (1) stereo component
and other items totalling an amount on Php 17,450. She took the items to the damage and prejudice of the Mr
and Mrs. Elnar. The RTC convicted the petitioner. On appeal, the CA affirmed the conviction but modified the
sentence. A motion for was denied by the CA. A petition for new trial was subsequently lodged by the
petitioner before the CA but was similarly denied. Hence, the present recourse which questions the
jurisdiction of RTC over the case.
II. Issue
Whether or not the petitioner is barred from assailing the jurisdiction of the RTC because of estoppel by
laches
III. Ruling
No. Municipal Trial Court has jurisdiction over the case and not the Regional Trial Court. In our legal system,
the question of jurisdiction may be raised at any stage of the proceedings. Whenever the question of
jurisdiction is put to front, courts should not lightly brush aside errors in jurisdiction especially when it is the
liberty of an individual which is at stake. The doctrine laid down in the Tijam case is an exception to and not
the general rule. Estoppel attached to the party assailing the jurisdiction of the court as it was the same party
who sought recourse in the said forum. In the case at bar, appellant cannot in anyway be said to have invoked
the jurisdiction of the trial court.
Whether or not the proper venue of perjury under Art. 183 of the RPC is the place where the Certificate
against Forum Shopping was notarized or where the Certification was presented to the trial court
III. Ruling
The place where the Certificate was notarized, the MeTC-Makati City, is the proper venue for the criminal
action. The constitutive act of the offense is the making of an affidavit, so, the criminal act is consummated
when the statement containing a falsity is subscribed and sworn before a duly authorized person.
The Court ruled that the crime of perjury committed through the making of a false affidavit under Art. 183 of
the RPC is committed at the time the affiant subscribes and swears to his or her affidavit since it is at that time
that all the elements of the crime of perjury are executed. When the crime is committed through false
testimony under oath in a proceeding that is neither criminal nor civil, venue is at the place where the
testimony under oath is given.
People v. Taroy
G.R. No. 192466, September 7, 2011, J. Abad
I. Facts
The public prosecutor charged the accused with two counts of rape before the RTC of La Trinidad, Benguet.
Upon conviction, the accused challenged the Benguet RTCs jurisdiction over the crimes charged, he having
testified that their residence when the alleged offenses took place was in Pucsusan Barangay, Baguio City. The
RTC held that said testimony did not strip the court of jurisdiction since he waived the jurisdictional
requirement. On appeal, the CA affirmed the decision of the RTC holding that the prosecution has sufficiently
established the jurisdiction of the RTC through the testimony of witnesses.
II. Issue
Whether or not RTC Benguet has jurisdiction over the case
III. Ruling
Yes. Venue is jurisdictional in criminal cases. It can neither be waived nor subjected to stipulation. The right
venue must exist as a matter of law. Thus, for territorial jurisdiction to attach, the criminal action must be
instituted and tried in the proper court of the municipality, city, or province where the offense was committed
or where any of its essential ingredients took place.
The uncorroborated assertion of Taroy that the offense was committed in Baguio cannot overturn the
testimonies of the witnesses and the allegations in the complaint. Besides, Taroy has already admitted in the
pre-trial that the RTC of Benguet has jurisdiction.