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FRANCISCO R. LLAMAS v. CA

FACTS:

The case involves a petition filed by the petitioners to annul the trial court's decision convicting them of "other form of swindling" under Article 316, paragraph 2, of the Revised Penal Code (RPC), on the ground of lack of jurisdiction. The petitioners were charged with the said crime and were found guilty beyond reasonable doubt by the Regional Trial Court (RTC) of Makati. The Court of Appeals affirmed the decision of the trial court. The petitioners then filed a petition for review before the Supreme Court, which was denied. The judgment of conviction became final and executory, and a warrant of arrest was subsequently issued. Petitioner Carmelita Llamas was arrested and served her jail term, while petitioner Francisco Llamas was not found. Francisco later moved for the lifting or recall of the warrant of arrest, raising the issue of lack of jurisdiction. When no action was taken by the trial court, the petitioners filed the present proceedings for the annulment of the trial and the appellate courts' decisions. The Court denied the petition, holding that the remedy of annulment of judgment cannot be availed of in criminal cases. The Court also ruled that the trial court had jurisdiction over the criminal case in question, based on the applicable law at the time of filing the information, which was Batas Pambansa Bilang 129. The Court further explained that the Metropolitan Trial Court (MeTC) could not have acquired jurisdiction over the case because its jurisdiction was limited to offenses punishable with a fine of not more than P4,000.00. Therefore, the petition was denied.

ISSUES:

  1. Whether or not the remedy of annulment of judgment can be availed of in criminal cases.

  2. Whether or not the trial court had jurisdiction over the offense charged.

RULING:

  1. The remedy of annulment of judgment cannot be availed of in criminal cases. Section 1, Rule 47 of the Rules of Court limits the scope of the remedy of annulment of judgment to civil actions, and the 2000 Revised Rules of Criminal Procedure itself does not permit such recourse. The Court held that there is no basis in law or the rules to extend the scope of Rule 47 to criminal cases.

  2. The trial court had jurisdiction over the offense charged. The statute in force at the time of the filing of the information was Batas Pambansa Bilang 129, which gave regional trial courts exclusive original jurisdiction in all criminal cases not within the exclusive jurisdiction of any other court, tribunal, or body. In this case, the offense charged falls under the jurisdiction of the regional trial court as it is punishable with imprisonment of not exceeding four years and two months, or a fine of not more than four thousand pesos, or both.

PRINCIPLES:

  • The remedy of annulment of judgment cannot be availed of in criminal cases. It is limited to civil actions and there is no basis in law or the rules to extend its scope to criminal cases.

  • Jurisdiction in criminal cases is determined by the statute in force at the time of the commencement of the action. The applicable law at the time of the filing of the information determines the jurisdiction of the court.

  • Regional trial courts have exclusive original jurisdiction in all criminal cases not within the exclusive jurisdiction of any other court, tribunal, or body, except those falling under the exclusive and concurrent jurisdiction of the Sandiganbayan. Metropolitan trial courts, municipal trial courts, and municipal circuit trial courts have jurisdiction over offenses punishable with imprisonment of not exceeding four years and two months, or a fine of not more than four thousand pesos, or both, except for offenses falling within the exclusive original jurisdiction of regional trial courts or the Sandiganbayan.