G.R. No. 147372 - Lanuza vs. Munoz

On June 19, 2001, private respondent Loverie Palacay filed a Criminal Complaint for Qualified Trespass to Dwelling against petitioner Estrella Taglay before the 5th Municipal Circuit Trial Court (MCTC) of Sta. Maria–Malita–Don Marcelino, Davao del Sur.
The Public Prosecutor found probable cause and filed an Information on November 19, 2001, accusing Taglay of unlawfully entering Palacay’s dwelling on June 2, 2001, and assaulting her, in violation of Article 280, RPC.

Arraignment was conducted on June 7, 2002, where petitioner pleaded not guilty. Pre-trial was set for August 13, 2002.
On August 15, 2002, upon certification that the offended party was a minor, the MCTC issued an order transferring the case to Branch 20, Regional Trial Court (RTC) of Digos City pursuant to R.A. No. 8369 (Family Courts Act) and A.M. No. 99-1-13-SC/Circular No. 11-99.

At the RTC (Branch 18), the prosecution presented witnesses. Before the last witness, petitioner moved to dismiss for lack of jurisdiction, arguing the MCTC should have dismissed rather than transferred the case and that no arraignment was held in the RTC.
On March 9, 2004, the RTC denied the Motion to Dismiss, holding:

Jurisdiction was validly acquired via transfer under Circular No. 11-99;
Any arraignment defect was cured by petitioner’s counsel’s participation in trial and cross-examination of witnesses.

Whether the RTC acquired jurisdiction through the MCTC’s transfer under A.M. No. 99-1-13-SC/Circular 11-99, given that the Information was filed after the circular’s effective date (March 1, 1999).

Whether petitioner’s failure to be arraigned before the RTC invalidated subsequent proceedings, considering that her arraignment before the MCTC was void for lack of jurisdiction.