Criminal Procedure
Isip v. People of the Philippines
Facts:
Petitioner Manuel Isip was charged with Estafa before
the RTC of Cavite City, after he allegedly received from
complainant, Atty. Jose, a seven-carat diamond men’s
ring valued at P200,000.00, for the purpose of selling the
same on commission basis and to deliver the proceeds of
the sale thereof or return the same if not sold. Petitioner
denied receiving the jewelry and failed to return the ring
or 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 Violation
of BP 22 (Bouncing Checks Law) after she issued checks in
payment for assorted pieces of jewelry she received from
Atty. Jose which were subsequently dishonoured for
insufficiency of funds. The complainant alleged that the
foregoing transactions happened at his ancestral house
in Cavite while he was on leave of absence from the
Bureau of Customs. In defense, petitioner averred that
the RTC had no jurisdiction over the case because he and
his 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 said
allegations. Upon appeal to the CA, Marietta Isip died
before any decision could have been promulgated
thereby 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 offense
imputed to petitioner and for which he was convicted.
Held:
Yes. The complainant had sufficiently shown that the
transaction took place in his home in Cavite. Since it has
been shown that venue was properly laid, it is now
petitioner’s task to prove otherwise. In the instant case,
petitioner failed to establish by sufficient and competent
evidence that the transaction happened in Manila due to
the following reasons:
a. Even if petitioner lives in Manila and the issued
checks were drawn against banks in Manila or
Makati, it still does not prove that the transactions
did not happen in Cavite. Distance will not prevent
any person from going to a distant place where he
can 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 are
generally conclusive and binding upon this Court.
Ballesteros.Beltran.Callangan.Carbonell.Falgui.Francisco.Ilagan.Ladringan.Maglaya.Martin.Ortinez.StaMaria.Villalva.Zabala
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The concept of venue of actions in criminal cases, unlike
in civil cases, is jurisdictional. The place where the crime
was committed determines not only the venue of the
action but is an essential element of jurisdiction. It is a
fundamental rule that for jurisdiction to be acquired by
courts in criminal cases:
a. The offense should have been committed; or
b. Any one of its essential ingredients should’ve taken
place within the court’s territorial jurisdiction.
Territorial jurisdiction in criminal cases is the territory
where the court has jurisdiction to take cognizance or to
try the offense allegedly committed therein. Thus, it
cannot take jurisdiction over a person charged with an
offense committed outside that territory. Furthermore,
the jurisdiction of a court over the criminal case is
determined by the allegations in the complaint or
information. Once it is so shown, the court may validly
take cognizance of the case. However, if the evidence
adduced during the trial shows that the offense was
committed somewhere else, the court should dismiss
the action for want of jurisdiction.
Landbank of the Philippines v. Belista
Facts:
Spouses Ralla donated 8 parcels of lot located in Albay to
their daughter, Rene Ralla Belista, herein private
respondent. Consequently, the 8 parcels of lot were
placed by DAR under the coverage of the Comprehensive
Agrarian Reform Program. Belista then claimed payment
of just compensation over said agricultural lands. DAR's
evaluation of the subject farms was only at P227,582.58,
while petitioner Land Bank assessed the same at
P317,259.31. Believing that her lots were grossly
underestimated, Belista filed a Petition for Valuation and
Payment of Just Compensation against Landbank before
the Regional Agrarian Reform Adjudicator (RARAD). The
RARAD issued a Decision wherein the just compensation
for the subject areas was fixed at P2,540,211.58.
Aggrieved, petitioner Landbank filed an original Petition
for Determination of Just Compensation at the the RTC.
The RTC dismissed the case for failure to exhaust
administrative remedies and/or comply with Sections 5,
6, and 7, Rule XIX of the 2003 DARAB Rules of Procedure.
Landbank lodged a MFR arguing that the DARAB Rules of
Procedure does not apply to Special Agrarian Courts but
the court a quo still denied its MFR. Petitioner Landbank
elevated the case before the CA through a Petition for
Review. The CA ruled that under the 2003 DARAB Rules
of Procedure, an appeal from the adjudicator's resolution
should be filed before the Department of Agrarian
Reform Adjudication Board (DARAB) and not before the
 Criminal Procedure
RTC and that petitioner's filing of the case before the RTC
without first seeking the intervention of the DARAB is
violative of the doctrine of non-exhaustion of
administrative remedies. Petitioner filed a MFR, but the
same 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 can
resort to the RTC sitting as a Special Agrarian Court.

Held:
No. Petitioner properly filed the petition before the RTC
and, hence, the RTC erred in dismissing the case.
Section 56 of RA 6657 provides that DAR is vested with
primary jurisdiction to determine and adjudicate agrarian
reform matters and shall have exclusive original
jurisdiction over all matters involving the implementation
of agrarian reform, except those falling under the
exclusive jurisdiction of the Department of Agriculture
and the Department of Environment and Natural
Resources. Section 57 of RA 6657 provides that the
Special Agrarian Court shall have original and exclusive
jurisdiction over all petitions for:
a) Determination of just compensation to landowners;
b) Prosecution of all criminal offenses under this Act.
Clearly, further exception to DAR's original and
exclusive jurisdiction are all petitions for determination
of just compensation to landowners and prosecution of
all criminal offenses under RA 6657, which are within
the original and exclusive jurisdiction of the RTC sitting
as a Special Agrarian Court. Jurisdiction over the subject
matter is conferred by law. Only a statute can confer
jurisdiction on courts and administrative agencies while
rules of procedure cannot.

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