Facts:

The case revolves around the petition filed by Felix O. Alfelor, Sr. and several other petitioners against the Honorable Bonifacio C. Intia, a municipal judge, and Felix A. Fuentebella, the respondent who initiated the complaint. The events pertain to an electoral contest in the 1965 congressional elections for the second district of Camarines Sur. Respondent Fuentebella was declared the winner, prompting Alfelor to file an electoral protest. Subsequently, Fuentebella accused Alfelor and the other petitioners of falsifying public or official documents related to the ballot box of a precinct located in Parubcan, Camarines Sur. However, the alleged criminal act was stated to have occurred in Iriga, Camarines Sur, which is outside the jurisdiction of the municipal court where the complaint was filed.

In response to Fuentebella's complaint, the petitioners filed a motion to dismiss, arguing that the municipal court did not have jurisdiction since the offense occurred in another

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Facts:

Parties and Background

• The case involves multiple petitioners, including Felix O. Alfelor, Sr., Remedios R. Alfelor, and others, who were challengers in an electoral context.
• The principal petitioner, Felix O. Alfelor, was a congressional candidate in the second district of Camarines Sur during the 1965 elections, contesting the proclamation of his opponent, respondent Felix A. Fuentebella, as the winner.

Alleged Offense and Venue of the Crime

• Respondent Fuentebella, in his complaint to the municipal court of Tigaon, Camarines Sur, charged the petitioners with the falsification of public and/or official documents.
• The documents in question were contained in a ballot box from a precinct in Parubcan, Camarines Sur, but the alleged act of falsification is stated to have occurred in another municipality, Iriga, Camarines Sur.
• The complaint raised the issue of venue, noting that the essential act of falsification may have taken place outside the territorial jurisdiction of the trial court in Tigaon.

Procedural Posture and Rulings at the Trial Level

• Petitioners filed a motion to dismiss the charge on the ground of lack of jurisdiction, arguing that the crime was committed in a different municipality (Iriga) than where the trial court (Tigaon) sits.
• Respondent Judge, presiding over the municipal court of Tigaon, denied the motion to dismiss based on his determination that falsification is a continuing offense.
• In support of his ruling, the Judge contended that one of the intervening municipalities, through which the jeep carrying the ballot box passed, was sufficient for asserting jurisdiction.
• A motion for reconsideration was subsequently filed by the petitioners, which was likewise denied, prompting the current petition for certiorari and prohibition.

Statutory and Case Law References Raised

• The petitioners relied on the Judiciary Act and the Rules of Court, which clearly state that municipal courts have original jurisdiction only over offenses committed within their territorial jurisdictions or where an essential ingredient of the crime occurred.
• The petitioners cited authoritative decisions, notably Lopez v. City Judge and several related U.S. and Philippine cases, to support the premise that falsification, once consummated at the moment the document is altered, establishes a fixed venue based on where that act occurred.

Issue:

Jurisdictional Inquiry

• Whether the municipal court of Tigaon, Camarines Sur, had proper jurisdiction to try a falsification case where the alleged consummated offense occurred in the municipality of Iriga.
• Whether the doctrine of falsification as a continuing offense can be used to extend jurisdiction beyond the territorial limits defined by the Judiciary Act and the Rules of Court.

Application of Statutory Provisions and Precedents

• Whether the trial court’s reliance on the notion that falsification is a continuing offense is consistent with established law and prior judicial decisions.
• Whether the jurisdictional rule mandating that the action be instituted where the crime is committed (or one of its essential ingredients occurred) mandates dismissal of the case in Tigaon.

Procedural and Evidentiary Considerations

• Whether the judge’s acceptance of the intervening municipality argument is legally tenable in light of the clear requirements of venue according to both the Judiciary Act and the Rules of Court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)