G.R. No. 18806 - Catigbac vs. Leyesa

On May 12, 1991, petitioner Wenefredo Calme, along with four other persons, was accused of killing Edgardo Bernal.
The method of murder involved allegedly throwing the victim overboard from the interisland passenger vessel M/V "Cebu City."
The vessel was owned and operated by William Lines, Inc. and was in the midst of its voyage from Ozamis City to Cebu City when the incident occurred.

The inquiry centers on the proper venue for trying the offense of murder.
Petitioner Calme challenged the jurisdiction of the Regional Trial Court (RTC), Branch 12 in Oroquieta City.
Calme contended that the applicable venue should be Siquijor based on the Marine Protest filed by the vessel’s captain, which noted that the ship was approximately 8.0 miles off Minalonan Point, Siquijor Island, at the time an incident involving a passenger (i.e., a passenger “jumped overboard”) was reported.
The petitioner argued that the general rule provided in paragraph (a) of Section 15 (now Section 14), Rule 110 of the Revised Rules of Court should govern because the exact location of the alleged crime was known.

A motion to quash the jurisdiction of the RTC, Branch 12 in Oroquieta City was filed by petitioner Calme but was denied by Judge Celso Conol.
Calme’s petition for certiorari and prohibition was dismissed by the Court of Appeals on December 10, 1993.
A subsequent motion for reconsideration of the Court of Appeals’ decision was likewise denied on July 14, 1994.
The present appeal focused solely on the issue of whether the RTC of Oroquieta City was the proper venue under the circumstances given that the offense was committed while the vessel was in transit.

Whether the Regional Trial Court of Oroquieta City (Branch 12) has jurisdiction over the murder charge committed on board a vessel in transit.

Whether the proper venue for the prosecution should be determined by pinpointing the exact location of the crime (as argued by the petitioner) or by applying Sec. 15(c), Rule 110 of the Revised Rules of Court, which governs offenses committed while a vessel is in transit.

Whether the petitioner’s reliance on Act No. 400 for determining venue is valid in light of the clear language of the current rule.