G.R. No. 182926 - Navaja vs. De Castro

Parties and Allegations
Petitioner Ana Lou B. Navaja served as Regional Sales Manager of private respondent DKT Philippines, Inc.
DKT alleged that on October 2, 2003, at Garden Café, Jagna, Bohol, Navaja falsified Receipt No. 6729 by altering the amount from ₱810.00 to ₱1,810.00 and used it to claim reimbursement.

Criminal Information and Evidence
Complaint-Affidavit dated February 18, 2004 (with Annex C – copy of altered receipt; Annex D – certified original receipt) charged falsification of a private document under Article 172(2) in relation to Article 171(6) of the Revised Penal Code.
Information filed on February 10, 2005 before MCTC Jagna-Garcia-Hernandez, Bohol as Criminal Case No. 2904 alleges that the falsification occurred in Jagna, within the court’s territorial jurisdiction.

Motions and Lower Court Proceedings
August 1, 2005 – Navaja filed a Motion to Quash and Defer Arraignment, arguing lack of venue since essential elements allegedly did not occur in Jagna, Bohol.
November 2, 2005 – MCTC denied the motion and set arraignment date.
January 24, 2006 – MCTC denied petitioner’s motion for reconsideration.

Certiorari and Appeals
September 21, 2006 – RTC of Loay, Bohol (Branch 50) dismissed petitioner’s petition for certiorari for lack of merit, upholding MCTC’s denial of motion to quash.
August 28, 2007 – Court of Appeals (CA) in CA-G.R. SP No. 02353 affirmed RTC’s order; May 7, 2008 – CA denied motion for reconsideration.
June 22, 2015 – Supreme Court rendered Decision denying petitioner’s Rule 45 petition for review on certiorari, affirming CA Decision and Resolution.

Whether the MCTC of Jagna-Garcia-Hernandez, Bohol, had jurisdiction over the criminal case for falsification of a private document (proper venue).
Whether the petitioner properly availed of certiorari to challenge the denial of her Motion to Quash for improper venue.
Whether jurisprudence permits filing of a certiorari petition to question denial of a motion to quash in criminal proceedings.