G.R. No. 67301 - Bala vs. Martinez

Manuel V. Bala was indicted for falsifying a public document by substituting the photo on a U.S. passport (Article 172, Revised Penal Code).
On January 3, 1978, the Court of First Instance of Manila found him guilty and sentenced him under the Indeterminate Sentence Law to 1 year and 1 day to 3 years, 6 months, and 21 days of prision correccional, plus a ₱1,800.00 fine.
The Court of Appeals affirmed the conviction on April 9, 1980.
After remand, on August 11, 1982, the trial court granted Bala a one-year probation with conditions including residence approval and supervision by a probation officer.

On September 23, 1982, Bala sought and obtained verbal permission from his probation officer to transfer residence within Las Piñas.
Although the probation term expired on August 10, 1983, no final discharge order was issued because the probation officer had not submitted his final report.
On December 8, 1983, the People moved to revoke probation, alleging violations of its terms. Bala opposed on January 4, 1984, claiming probation had already lapsed.
The probation officer filed conflicting motions—first to terminate probation, then to recommend revocation based on new evidence—and submitted a supplemental report on January 30, 1984.
On April 2, 1984, Branch XX of the RTC of Manila denied Bala’s motion to dismiss the revocation proceeding for lack of jurisdiction. Bala then filed a petition for certiorari.

Does the expiration of the probation period, absent a court order of final discharge, terminate the court’s jurisdiction to revoke probation?
Does a probationer’s change of residence automatically transfer venue and supervision to another court under Section 13, P.D. No. 968, and is verbal permission by the probation officer sufficient?