Title
Lopez vs. City Judge
Case
G.R. No. L-25795
Decision Date
Oct 29, 1966
Parties disputed jurisdiction over a falsification case; Supreme Court ruled Angeles City lacked jurisdiction as the offense occurred outside its territorial limits.
A

Case Digest (G.R. No. L-25795)

Facts:

Angelina Mejia Lopez, Aurora Mejia Villasor, Roy P. Villasor v. The City Judge, Cesar L. Paras, Trinidad T. Lazatin, and Terra Development Corporation, G.R. No. L-25795, October 29, 1966, the Supreme Court En Banc, Dizon, J., writing for the Court.

In February 1964, petitioners — Roy P. Villasor (as administrator of the intestate estate of Manuel M. Mejia and Gloria Laza tin), Angelina Mejia Lopez, Aurora Mejia Villasor, and other heirs — entered into a development and subdivision contract with Trinidad T. Lazatin concerning three parcels of land that formed part of the intestate estate (Special Proceedings No. 48181, Court of First Instance of Manila). Lazatin later transferred his rights under that contract to Terra Development Corporation.

Months later the heirs (including petitioners) sued for rescission of the development contract in the Court of First Instance of Quezon City (Civil Case No. Q-8344). In response, Lazatin and Terra Development Corporation filed a complaint with the City Fiscal of Angeles alleging violations of Article 172 in relation to Article 171(4) of the Revised Penal Code. After a preliminary examination the Fiscal filed an information in the City Court of Angeles City charging the petitioners with falsification of a private document (Criminal Case No. C-2268), alleging that petitioners falsely represented in the contract that Aurora and Angelina were guardians of two minors when, they alleged, Carolina M. de Castro was the judicial guardian at the time.

To allow presentation of exculpatory evidence, the City Fiscal of Angeles reinvestigated the complaint on March 7, 1965. The defendants repeatedly postponed arraignment while the motion to dismiss for lack of territorial jurisdiction remained pending. On November 26, 1965 the petitioners filed a motion to quash the information in the City Court on the ground that the alleged falsification occurred outside Angeles City (they claimed the signings occurred in Makati and Quezon City). With the City Fiscal’s conformity the complainants opposed the motion. On February 3, 1966 the respondent judge denied the motion to quash and reset arraignment for March 5, 1966. Thereupon petitioners filed the present action in the Supreme Court seeking writs of certiorari and prohibition to restrain the City Court of Angeles from proceeding.

Issues:

  • Is the petition for certiorari and prohibition properly entertained to challenge the City Court of Angeles’ denial of the motion to quash?
  • Does the City Court of Angeles have jurisdiction to try Criminal Case No. C-2268 for alleged falsification of a private document?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.