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CRIMPRO DIGESTS G01 TOPIC: CRIMINAL JURISDICTION

ATTY. ARNO V. SANIDAD AUTHOR: Caro, Monica Celine A.


15) People v. Pilotin, 65 SCRA 635, 31 July 1975 - Asked to comment on the motion, Provincial Fiscal of Ilocos Sur
Plaintiff-appellee: People of the Philippines assented to the transfer of the trial venue to the New Bilibid
Defendants-appellants: Camilo Pilotin, Vincent Crisologo, Isidro Pugal, Prisons
Erning Abano
ISSUE/S: W/N the venue of Crisologos trial may be transferred given the
RECIT READY: Crisologo motioned to be transferred to the New Bilibid facts of the case? YES.
prison on the ground that his life would be in jeopardy at the Vigan
municipal jail due to his many political enemies. SC granted the motion to HELD: Section 5(4), Article X of the Constitution expressly empowers this
avoid a miscarriage of justice and because it would be absurd to compel Court to order a change of venue or place of trial to avoid a miscarriage of
him to undergo trial in a place where his life would be imperiled. justice. Here, what is involved is not merely a miscarriage of justice but
the personal safety of movant Crisologo, the accused. It would be absurd
DOCTRINE: Section 5(4), Article X of the Constitution expressly empowers to compel him to undergo trial in a place where his life would be imperiled.
the Supreme Court to order a change of venue or place of trial to avoid a
miscarriage of justice. Present hostile sentiment against the accused at Present hostile sentiment against the accused at the place of trial is a
the place of trial is a justification for transfer of venue. Change of venue justification for transfer of venue. The change of venue involves not merely
involves not merely the change of the place of hearing but also the transfer the change of the place of hearing but also the transfer of the expediente
of the expediente (casefile) of his case to another court of his case to another court.

FACTS: Notes - The Constitution has vested the Judicial Power in the Supreme
- Vincent Crisologo filed a verified motion to be transferred to the Court and such inferior courts as may be established by law (Article VIII,
New Bilibid Prison or alternatively, to Camps Crame, Aguinaldo, or Section 13, [1937 Constitution]), and such judicial power connotes certain
Olivas, of the place of trial of a criminal case instituted in the MTC incidental and inherent attributes reasonably necessary for an effective
of Vigan, Ilocos Sur, where he was charged with illegal possession administration of justice. One of these incidental and inherent powers of
of firearms and ammunitions courts is that of transferring the trial of cases from one court to another of
- He alleged that his life would be in jeopardy if he were to be equal rank in a neighboring site, whenever the imperative of securing a fair
confined in the Vigan municipal jail because of the many political and impartial trial, or of preventing a miscarriage of justice, so demands.
enemies his family had in that area (i.e., his father was shot to
death while hearing mass at the Vigan cathedral).