PEOPLE vs PILOTIN

July 31, 1975

ADMINISTRATIVE POWERS OF THE SC: change in venue
Doctrine: The Supreme Court is empowered to "order a change of venue or place of trial to void a miscarriage
of justice."
Summary: Crisologo was charged with illegal possession of firearms and ammunitions. He filed a motion
praying for the transfer of his case to the New Bilibid Prisons or to Camp Crame, Aguinaldo, or Olivas. He
claimed that if he were confined in Vigan municipal jail, his life would be in jeopardy due to the many enemies
of his family. He even cited instances wherein his family members were murdered in the city. Provincial Fiscal
of Ilocos Sur conformed with the transfer.

Facts:
• Crisologo was charged with illegal possession of firearms and ammunitions in Vigan
• Crisologo filed a motion to have his case transferred to a different venue because his life would be in
peril if made to be confined in the Vigan municipal jail
• Cited instances wherein his family members were murdered, his father, a congressman, even
assassinated
• Claimed he would be a “sitting duck” if made to stay in Vigan municipal jail

Issue: w/n Crisologo’s motion for transfer should be granted à YES

Court Ruling: municipal court of Vigan is directed to transfer the record of Criminal Case No. 3949 to
the City Court of Quezon City
• Section 5(4), Article X of the Constitution
o SC allowed to order a change of venue or place of trial to avoid miscarriage of justice
• Present hostile sentiment against the accused is a justification for the transfer
• Not just miscarriage of justice involved but also the safety of the accused
• Alleged evidence against him is in Camp Crame à Case to be transferred to QC Court; trial to be held
at Camp Crame
o Most convenient arrangement