Navaja vs. De Castro

G.R. No. 182926
Ana Lou B. Navaja falsified a receipt in Jagna, Bohol, inflating P810 to P1,810 for reimbursement. Courts upheld jurisdiction, ruling venue proper; certiorari improper for motion denial. SC affirmed lower courts.
jurisdiction falsification of private document motion to quash

Case Digest (G.R. No. 182926)

Facts:

Ana Lou B. Navaja v. Hon. Manuel A. De Castro, or the Acting Presiding Judge of MCTC Jagna‑Garcia‑Hernandez, DKT Phils., Inc., represented by Atty. Edgar Borje, G.R. No. 182926, June 22, 2015, Supreme Court Third Division, Peralta, J., writing for the Court.

Petitioner is Ana Lou B. Navaja; respondents are Hon. Manuel A. De Castro (acting presiding judge of the MCTC of Jagna‑Garcia‑Hernandez) and DKT Philippines, Inc., represented by Atty. Edgar Borje. Private respondent filed a Complaint‑Affidavit alleging that while petitioner was its Regional Sales Manager she falsified a Garden Cafe receipt by altering P810.00 to P1,810.00 and claimed reimbursement.

An Information for falsification of a private document was filed before the Municipal Circuit Trial Court (MCTC) of Jagna‑Garcia‑Hernandez as Criminal Case No. 2904. On August 1, 2005, petitioner moved to quash and to defer arraignment, contending venue was improper because none of the essential elements of falsification occurred in Jagna. The MCTC denied the motion in an Order dated November 2, 2005 and, after petitioner’s motion for reconsideration was denied on January 24, 2006, petitioner filed a petition for certiorari before the Regional Trial Court (RTC) of Loay, Bohol.

The RTC denied the certiorari petition in an Order dated September 21, 2006, finding that the allegations in the Information and the complaint‑affidavit, as well as the Regional State Prosecutor’s resolution referencing the sworn statement of a cashier (Cherly/Labarro) who said petitioner borrowed her pen and wrote on the receipt, established probable cause that the falsification occurred in Jagna. Petitioner elevated the matter to the Court of Appeals (CA), which, in a Decision dated August 28, 2007 (and denied reconsideration May 7, 2008), affirmed the RTC...(Pro-only)

Issues:

  • Is a petition for review under Rule 45 a proper remedy to assail the denial of a motion to quash an information?
  • Did the MCTC of Jagna‑Garcia‑Hernandez have jurisdiction (proper venue) to try petitioner for falsification of a private document?
  • Does the absence of actual damage at the time the receipt was issued negate the crime of falsifi...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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