Case Digest (G.R. No. L-27590)
Facts:
- In "Alfelor, Sr. v. Intia" (G.R. No. L-27590), decided on April 30, 1976, Felix O. Alfelor, Sr. and other petitioners filed a petition for certiorari and prohibition.
- The respondents were Honorable Bonifacio C. Intia, Municipal Judge of Tigaon, Camarines Sur, and Felix A. Fuentebella.
- The case stemmed from the 1965 congressional elections in the second district of Camarines Sur.
- Alfelor, Sr., a defeated candidate, filed an election protest against Fuentebella, the proclaimed winner.
- Fuentebella charged Alfelor and other petitioners with falsification of public or official documents contained in a ballot box from a precinct in Parubcan, Camarines Sur.
- The alleged falsification occurred in Iriga, Camarines Sur.
- Petitioners moved to dismiss the case, arguing that the Municipal Court of Tigaon lacked jurisdiction since the offense was committed in a different municipality.
- Judge Intia denied the motion, claiming falsification is a continuing offense and his court had jurisdiction as the jeep carrying the ballot box passed through Tigaon.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Municipal Court of Tigaon, Camarines Sur, lacked jurisdiction over the charge of falsification of public documents as the offense was committed in another municipality. ...(Unlock)
Ratio:
- The Supreme Court, through Acting Chief Justice Fernando, emphasized that under the Judiciary Act and the Rules of Court, the jurisdiction of municipal courts to try criminal cases is confined to offenses committed within their respective territorial jurisdictions.
- This principle was reiterated in several cases, including Lopez v. City Judge and U.S. v. Pagdayuman.
- The Court clarified that the place where the criminal offense was committed determines the venue and is an essential elemen...continue reading
Case Digest (G.R. No. L-27590)
Facts:
In the case of "Alfelor, Sr. v. Intia" (G.R. No. L-27590), decided on April 30, 1976, the principal petitioner, Felix O. Alfelor, Sr., along with several other petitioners, filed a petition for certiorari and prohibition against the Honorable Bonifacio C. Intia, the Municipal Judge of Tigaon, Camarines Sur, and Felix A. Fuentebella. The case arose from the 1965 congressional elections in the second district of Camarines Sur, where Alfelor, Sr., a defeated candidate, filed an election protest against Fuentebella, the proclaimed winner. In response, Fuentebella charged Alfelor and other petitioners with falsification of public or official documents contained in a ballot box from a precinct in Parubcan, Camarines Sur. The alleged falsification occurred in another municipality, Iriga, Camarines Sur. The petitioners moved to dismiss the case on the grounds of lack of jurisdiction, arguing that the municipal court of Tigaon did not have jurisdiction over the offense since it was committed in a different municipality. However, Judge Intia denied the motion, asserting that falsification is a continuing offense and that his court had jurisdiction as t...