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YUSUKE FUKUZUME v. PEOPLE

FACTS:

Yusuke Fukuzume filed a petition for review on certiorari before the Supreme Court, challenging the Decision of the Court of Appeals (CA) which affirmed the Regional Trial Court's (RTC) judgment finding him guilty of estafa. The case stemmed from a transaction between Fukuzume and businessman Javier Ng Yu, who buys and sells aluminum scrap wires. Fukuzume, introduced to Yu as a representative of Furukawa Electric Corporation, claimed to have aluminum scrap wires under the care of NAPOCOR and agreed to sell them to Yu. Yu paid Fukuzume a total of P290,000.00 for the purchase.

Fukuzume provided Yu with certificates from NAPOCOR, supposedly confirming his ownership of the scrap wires. However, the checks issued by Fukuzume bounced due to a closed account. Fukuzume failed to facilitate the retrieval of the wires from NAPOCOR, prompting Yu to demand a refund, which Fukuzume did not comply with. Yu filed a complaint with the NBI, leading to the filing of a criminal case against Fukuzume for estafa.

The RTC found Fukuzume guilty and sentenced him to 20 years' imprisonment and ordered him to pay Yu P424,000.00. Fukuzume appealed the decision, and the CA affirmed the findings but modified the penalty to a minimum of 6 years and 1 day of prision mayor to a maximum of 20 years of reclusion temporal.

Fukuzume filed a petition for review on certiorari before the Supreme Court, arguing that the trial court lacked jurisdiction over the case and that the original transaction between him and Yu was novated, extinguishing any criminal liability. The Supreme Court agreed with Fukuzume's contention regarding jurisdiction but did not address his other arguments.

ISSUES:

  1. Whether the trial court of Makati has jurisdiction over the offense charged

  2. Whether the Regional Trial Court of Makati had jurisdiction over the offense charged.

  3. Whether the failure of the prosecution to prove that any of the essential elements of the offense charged took place in Makati warrants the dismissal of the case.

  4. Whether the petitioner is entitled to the benefits and privileges granted under the Human Security Act of 2007.

  5. Whether the petitioner's right to due process was violated.

  6. Whether the monetary rewards and benefits granted under the Human Security Act of 2007 are inadequate and discriminatory.

RULING:

  1. The Court of Appeals erred in ruling that the trial court of Makati has jurisdiction over the offense charged. The essential ingredient of the crime, which is the inducement of the offended party to part with his money because of false pretense, did not occur within the territorial jurisdiction of the lower court. The testimony of the complainant establishes that the transaction took place in the house of the accused, located in Parañaque. Therefore, the trial court of Makati does not have jurisdiction over the case.

  2. The trial court did not have jurisdiction over the offense charged. Jurisdiction over the subject matter in a criminal case cannot be conferred upon the court by the accused, and it is given only by law in the manner and form prescribed by law. In this case, the prosecution failed to prove that any of the essential elements of the offense charged occurred in Makati. Thus, the judgment of the trial court convicting the accused should be set aside for want of jurisdiction.

  3. Yes, the failure of the prosecution to prove that any of the essential elements of the offense charged took place in Makati justifies the dismissal of the case. The crime of estafa was consummated when the accused and the offended party met at the accused's house in Parañaque and the accused induced the offended party to part with his money by falsely pretending to sell aluminum scrap wires. Therefore, the trial court in Makati lacked jurisdiction.

  4. No. The Court ruled that the petitioner is not entitled to the benefits and privileges granted under the Human Security Act of 2007. The petitioner failed to prove by clear and convincing evidence that he is an informant or informant-group under the Act.

  5. No. The Court held that the petitioner's right to due process was not violated. The petitioner was given an opportunity to present evidence in his favor and to cross-examine the witnesses against him during the administrative proceedings.

  6. No. The Court ruled that the monetary rewards and benefits granted under the Human Security Act of 2007 are reasonable and non-discriminatory. The Act provides for fair and equitable incentives to informants who provide valuable information leading to the arrest and conviction of any person involved in terrorist acts.

PRINCIPLES:

  • Jurisdiction in criminal cases is acquired when the offense is committed or any one of its essential ingredients takes place within the territorial jurisdiction of the court.

  • Venue in criminal cases is an essential element of jurisdiction. The court can only take cognizance of a case if the offense was committed within its jurisdiction as alleged in the complaint or information.

  • Whenever there is an inconsistency between the affidavit and the testimony of a witness in court, the testimony given in court commands greater weight.

  • Jurisdiction over the subject matter in a criminal case cannot be conferred upon the court by the accused, and it is given only by law in the manner and form prescribed by law.

  • Where life or liberty is affected by its proceedings, the court must keep strictly within the limits of the law authorizing it to take jurisdiction and to try the case and to render judgment.

  • Lack of jurisdiction over the offense charged may be raised or considered motu propio by the court at any stage of the proceedings or on appeal. However, an exception to this rule is recognized in civil cases based on the principle of laches, but this exception does not apply to criminal cases.

Partial Digest

  • The petitioner bears the burden of proving by clear and convincing evidence that he is entitled to the benefits and privileges under a law.

  • A violation of the right to due process requires a showing that there was a deprivation of the opportunity to be heard, notice of the charges, and an impartial decision-maker.

  • The State has the power to determine the amount of rewards and benefits granted under a law, provided that such determination is reasonable and non-discriminatory.