A.
Venue in Criminal Cases is Jurisdictional petitioner failed to establish by sufficient and competentevidence that
Isip v. People of the Philippines
Facts:
Petitioner Manuel Isip was charged with Estafa beforethe RTC of
Cavite City, after he allegedly received fromcomplainant, Atty. Jose, a
seven-
carat diamond men’s
ring valued at P200,000.00, for the purpose of selling thesame on
commission basis and to deliver the proceeds of the sale thereof or
return the same if not sold. Petitionerdenied receiving the jewelry and
failed to return the ringor proceeds of the sale even after repeated
demand. On
the other hand, petitioner’s wife, Marietta Isip, was
indicted before the same court for 7 counts of Violationof BP 22
(Bouncing Checks Law) after she issued checks inpayment for
assorted pieces of jewelry she received fromAtty. Jose which were
subsequently dishonoured forinsufficiency of funds. The complainant
alleged that theforegoing transactions happened at his ancestral
housein Cavite while he was on leave of absence from theBureau of
Customs. In defense, petitioner averred thatthe RTC had no
jurisdiction over the case because he andhis wife had transactions
with the complainant at the
latter’s residence located at Plaza Tower Condominium in
Manila as both of them were also Manila residents.Despite this, the
trial court found them guilty of the saidallegations. Upon appeal to the
CA, Marietta Isip diedbefore any decision could have been
promulgatedthereby extinguishing her criminal and civil
liability.However, the CA still affirmed
Manuel Isip’s conviction
for estafa, hence this appeal.
Issue:
Whether the trial court had jurisdiction over the offenseimputed to
petitioner and for which he was convicted.
Held:
Yes. The complainant had sufficiently shown that thetransaction took
place in his home in Cavite. Since it hasbeen shown that venue was
properly laid, it is now
petitioner’s task to prove otherwise. In the instant case,
the transaction happened in Manila due tothe following reasons:a.
Even if petitioner lives in Manila and the issuedchecks were drawn
against banks in Manila orMakati, it still does not prove that the
transactionsdid not happen in Cavite. Distance will not preventany
person from going to a distant place where hecan procure goods he
can sell to earn a living.b.
It is settled that when the RTC ’s findings have been affirmed by the
appellate court, said findings aregenerally conclusive and binding
upon this Court.
The concept of venue of actions in criminal cases, unlikein civil cases,
is jurisdictional. The place where the crimewas committed determines
not only the venue of theaction but is an essential element of
jurisdiction. It is afundamental rule that for jurisdiction to be acquired
bycourts in criminal cases:a.
The offense should have been committed; orb.
Any one of its essential ingredients should’ve takenplace within the
court’s territorial jurisdiction.Territorial jurisdiction in criminal cases is
the territorywhere the court has jurisdiction to take cognizance or totry
the offense allegedly committed therein. Thus, itcannot take
jurisdiction over a person charged with anoffense committed outside
that territory. Furthermore,the jurisdiction of a court over the criminal
case isdetermined by the allegations in the complaint
orinformation. Once it is so shown, the court may validlytake
cognizance of the case. However, if the evidenceadduced during the
trial shows that the offense wascommitted somewhere else, the court
should dismissthe action for want of jurisdiction.
Landbank of the Philippines v. Belista
Facts:
Spouses Ralla donated 8 parcels of lot located in Albay totheir
daughter, Rene Ralla Belista, herein privaterespondent.
Consequently, the 8 parcels of lot wereplaced by DAR under the
coverage of the ComprehensiveAgrarian Reform Program. Belista
then claimed paymentof just compensation over said agricultural
lands. DAR'sevaluation of the subject farms was only at
P227,582.58,while petitioner Land Bank assessed the same atP317,2 b)
59.31. Believing that her lots were grosslyunderestimated, Belista filed
a Petition for Valuation andPayment of Just Compensation against Prosecution of all criminal offenses under this Act.
Landbank beforethe Regional Agrarian Reform Adjudicator (RARAD). Clearly, further exception to DAR's original andexclusive jurisdiction
TheRARAD issued a Decision wherein the just compensationfor the are all petitions for determinationof just compensation to landowners
subject areas was fixed at P2,540,211.58.Aggrieved, petitioner and prosecution of all criminal offenses under RA 6657, which are
Landbank filed an original Petitionfor Determination of Just withinthe original and exclusive jurisdiction of the RTC sittingas a
Compensation at the the RTC.The RTC dismissed the case for failure Special Agrarian Court. Jurisdiction over the subjectmatter is
to exhaustadministrative remedies and/or comply with Sections 5,6, conferred by law. Only a statute can confer jurisdiction on courts and
and 7, Rule XIX of the 2003 DARAB Rules of Procedure.Landbank administrative agencies whilerules of procedure cannot.
lodged a MFR arguing that the DARAB Rules of Procedure does not
apply to Special Agrarian Courts butthe court a quo still denied its
MFR. Petitioner Landbankelevated the case before the CA through a
Petition forReview. The CA ruled that under the 2003 DARAB Rulesof
Procedure, an appeal from the adjudicator's resolutionshould be filed
before the Department of AgrarianReform Adjudication Board
(DARAB) and not before the RTC and that petitioner's filing of the
case before the RTC without first seeking the intervention of the
DARAB isviolative of the doctrine of non-exhaustion of administrative
remedies. Petitioner filed a MFR, but thesame was denied, hence, this
petition.

Issue:
Whether it is necessary that in cases involving claims for just
compensation under RA 6657, the RARAD
’s Decision
must first be appealed to DARAB before a party canresort to the RTC
sitting as a Special Agrarian Court.
Held:
No. Petitioner properly filed the petition before the RTCand, hence,
the RTC erred in dismissing the case.Section 56 of RA 6657 provides
that DAR is vested withprimary jurisdiction to determine and
adjudicate agrarianreform matters and shall have exclusive
original jurisdiction over all matters involving the implementationof
agrarian reform, except those falling under theexclusive jurisdiction of
the Department of Agricultureand the Department of Environment and
NaturalResources.
Section 57 of RA 6657 provides that theSpecial Agrarian Court shall
have original and exclusive jurisdiction over all petitions for:a)

Determination of just compensation to landowners;