Case Digest (G.R. No. 172142)
Facts:
The case involves David B. Campanano, Jr. as the petitioner and Jose Antonio A. Datuin as the respondent. The events leading to this case began with a complaint for Estafa filed by Seishin International Corporation, represented by Campanano, against Datuin. An Information for violation of Batas Pambansa Blg. 22 was subsequently filed against Datuin, leading to his conviction by the Regional Trial Court, Branch 71 of Pasig City, on May 3, 1999. Datuin appealed the conviction, but the Court of Appeals and the Supreme Court dismissed his appeals, making the decision final and executory on October 24, 2003.
In a turn of events, Datuin claimed that the complaint against him was "false, unfounded, and malicious" based on newly discovered evidence—a cash voucher dated June 28, 1993, which he alleged proved he had fully paid for two roadrollers purchased from Seishin International Corporation. Datuin filed a complaint for Incriminating Innocent Persons against Campanano ...
Case Digest (G.R. No. 172142)
Facts:
Background of the Case
- Petitioner David B. Campanano, Jr., representing Seishin International Corporation, filed a complaint for Estafa against respondent Jose Antonio Datuin.
- An Information for violation of Batas Pambansa Blg. 22 (Bouncing Checks Law) was filed against Datuin.
- The Regional Trial Court (RTC) of Pasig City convicted Datuin of Estafa on May 3, 1999. Datuin's appeals to the Court of Appeals and the Supreme Court were dismissed, and the decision became final and executory on October 24, 2003.
Newly Discovered Evidence
- Datuin later claimed to have discovered new evidence—a cash voucher dated June 28, 1993—proving he had fully paid for the two roadrollers, which were the subject of the Estafa case.
- Based on this, Datuin filed a complaint for Incriminating Against Innocent Persons under Article 363 of the Revised Penal Code against Campanano and Yasunobu Hirota before the Office of the City Prosecutor of Quezon City.
Prosecutor's Dismissal
- The Quezon City Prosecutor dismissed Datuin's complaint on January 20, 2004, citing lack of jurisdiction since the Estafa case was filed and tried in Pasig City.
- The Department of Justice (DOJ) upheld the dismissal on August 20, 2004, finding no error in the prosecutor's resolution.
Court of Appeals' Decision
- The Court of Appeals reversed the DOJ's decision on December 9, 2005, ruling that the Quezon City Prosecutor had jurisdiction because Campanano's counter-affidavit was executed in Quezon City. The case was remanded for further investigation.
Issue:
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Ruling:
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Ratio:
Jurisdiction and Venue
- Venue is an essential element of jurisdiction in criminal cases. The jurisdiction of a court is determined by the allegations in the complaint or information.
- Under Section 15(a) of Rule 110 of the Revised Rules on Criminal Procedure, a criminal action must be instituted and tried in the court of the municipality or territory where the offense was committed or where any of its essential ingredients occurred.
- Datuin's complaint-affidavit did not allege that the crime of Incriminating Against Innocent Persons or any of its essential ingredients occurred in Quezon City. The only reference to Quezon City was Datuin's residence, which is insufficient to establish jurisdiction.
- The Court of Appeals erred in ruling that the execution of Campanano's counter-affidavit in Quezon City conferred jurisdiction on the Quezon City Prosecutor's Office.
Elements of Incriminating Against Innocent Persons
- Article 363 of the Revised Penal Code penalizes acts that directly incriminate or impute the commission of a crime to an innocent person, provided the act does not constitute perjury.
- The crime requires: (1) an act by the offender, (2) the act directly incriminates or imputes a crime to an innocent person, and (3) the act does not constitute perjury.
- Datuin's complaint alleged that Campanano and Hirota falsely accused him of Estafa, but this does not fall under Article 363, which pertains to acts like planting evidence, not malicious prosecution or false testimony.
- The Supreme Court clarified that Article 363 does not cover malicious prosecution or false testimony, which are distinct from acts directly causing false prosecutions.
Finality of Estafa Conviction
- Datuin's conviction for Estafa had already become final and executory. This bars the filing of a criminal case for false testimony or malicious prosecution against Campanano.
Conclusion:
The Supreme Court held that the Quezon City Prosecutor's Office lacked jurisdiction over Datuin's complaint. Additionally, the allegations in the complaint did not establish probable cause for the crime of Incriminating Against Innocent Persons under Article 363 of the Revised Penal Code. The Court of Appeals' decision was reversed, and Datuin's complaint was dismissed.