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Venue in Criminal Cases is Jurisdictional petitioner failed to establish by sufficient and competentevidence that
Isip v. People of the Philippines the transaction happened in Manila due tothe following reasons:a.

Facts: Even if petitioner lives in Manila and the issuedchecks were drawn
against banks in Manila orMakati, it still does not prove that the
Petitioner Manuel Isip was charged with Estafa beforethe RTC of transactionsdid not happen in Cavite. Distance will not preventany
Cavite City, after he allegedly received fromcomplainant, Atty. Jose, a person from going to a distant place where hecan procure goods he
seven- can sell to earn a living.b.
carat diamond men’s
ring valued at P200,000.00, for the purpose of selling thesame on It is settled that when the RTC ’s findings have been affirmed by the
commission basis and to deliver the proceeds of the sale thereof or appellate court, said findings aregenerally conclusive and binding
return the same if not sold. Petitionerdenied receiving the jewelry and upon this Court.
failed to return the ringor proceeds of the sale even after repeated The concept of venue of actions in criminal cases, unlikein civil cases,
demand. On is jurisdictional. The place where the crimewas committed determines
the other hand, petitioner’s wife, Marietta Isip, was not only the venue of theaction but is an essential element of
indicted before the same court for 7 counts of Violationof BP 22 jurisdiction. It is afundamental rule that for jurisdiction to be acquired
(Bouncing Checks Law) after she issued checks inpayment for bycourts in criminal cases:a.
assorted pieces of jewelry she received fromAtty. Jose which were
subsequently dishonoured forinsufficiency of funds. The complainant The offense should have been committed; orb.
alleged that theforegoing transactions happened at his ancestral
housein Cavite while he was on leave of absence from theBureau of Any one of its essential ingredients should’ve takenplace within the
Customs. In defense, petitioner averred thatthe RTC had no court’s territorial jurisdiction.Territorial jurisdiction in criminal cases is
jurisdiction over the case because he andhis wife had transactions the territorywhere the court has jurisdiction to take cognizance or totry
with the complainant at the the offense allegedly committed therein. Thus, itcannot take
latter’s residence located at Plaza Tower Condominium in jurisdiction over a person charged with anoffense committed outside
Manila as both of them were also Manila residents.Despite this, the that territory. Furthermore,the jurisdiction of a court over the criminal
trial court found them guilty of the saidallegations. Upon appeal to the case isdetermined by the allegations in the complaint
CA, Marietta Isip diedbefore any decision could have been orinformation. Once it is so shown, the court may validlytake
promulgatedthereby extinguishing her criminal and civil cognizance of the case. However, if the evidenceadduced during the
liability.However, the CA still affirmed trial shows that the offense wascommitted somewhere else, the court
Manuel Isip’s conviction should dismissthe action for want of jurisdiction.
for estafa, hence this appeal.
Landbank of the Philippines v. Belista
Whether the trial court had jurisdiction over the offenseimputed to Facts:
petitioner and for which he was convicted.
Spouses Ralla donated 8 parcels of lot located in Albay totheir
Held: daughter, Rene Ralla Belista, herein privaterespondent.
Yes. The complainant had sufficiently shown that thetransaction took Consequently, the 8 parcels of lot wereplaced by DAR under the
place in his home in Cavite. Since it hasbeen shown that venue was coverage of the ComprehensiveAgrarian Reform Program. Belista
properly laid, it is now then claimed paymentof just compensation over said agricultural
petitioner’s task to prove otherwise. In the instant case, 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

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.
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
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;