Case No.

1 | Transfer of Venue or Place of Trial compel the accused to undergo trial in a place
where his life would be imperiled.

The change of venue involves NOT merely the

PEOPLE v. CAMILO PILOTIN ET AL.
G.R. Nos. L-35377-78, July 31, 1975
Thesis Statement:
Vincent Crisologo through his counsel filed a
verified motion praying for the transfer of the
venue of trial of his case (Criminal Case No. 3949)
from the Municipal Court of Vigan, Ilocos Sur to the
New Bilibid Prisons or to Camps Crame, Aguinaldo
or Olivas due to the present hostile sentiment
against the accused Crisologo.
Facts:
Vincent Crisologo was charged with illegal
possession of firearms and ammunitions in the
municipal court of Vigan, Ilocos Sur.
change of the place of hearing but also the
transfer of the expediente (a collection of
papers containing detailed information about
the case) of the Criminal Case No. 3949 to
another court. Since the alleged evidence against
him is in the custody of the authorities at Camp
Crame, Quezon City, the transfer of Criminal Case
No. 3949 to the City Court of Quezon City and the
holding of the trial at the Camp Crame appear to be
the most convenient arrangement.
WHEREFORE, the municipal court of Vigan is
directed to transfer the record of Criminal Case No.
3949 to the City Court of Quezon City where it should
be re-docketed and raffled to any Judge thereof. The
case may be tried at Camp Crame. The usual
precautions and security measures should be
adopted in bringing defendant Crisologo to Camp
Crame on the occasion of the hearing.

Incidents like the murder of the Crisologos’

supporters, murder of his father, Cong. Floro
Crisologo, the fear of no protection from
assassination attempts against him inside the jail,
and fearing he could be murdered on the pretext
that he was trying to escape put his life in jeopardy.
In addition, the Crisologos have many political
enemies within the vicinity of the Vigan Municipal
jail.

The Provincial Fiscal of Ilocos Sur agreed to the

transfer of venue of the trial to the New Bilibid
Prisons in his comment to the motion.

Issue/s:

WON the motion of the accused Crisologo to

transfer the venue of the trial is meritorious.

Ruling:

Yes. The motion to transfer the venue of the trial is

meritorious because the present hostile sentiment
against the accused at the place of trial is a just
cause for the transfer of venue.

Sec 5(4), Article X of the Constitution expressly

empowers the Supreme Court to “order a
change of venue or place of trial to avoid a
miscarriage of justice.” The present hostile
sentiment against the accused does not merely
involve a miscarriage of justice but also his
personal safety is also at risk. It would be absurd to