FACTS:

The case involves a complaint-affidavit filed against the accused, alleging that she committed theft through falsification of documents. According to the complaint-affidavit, the accused, while employed by DKT Company, embezzled an amount of Php1,000.00 for her own benefit, causing damage to the company. It is further alleged that the accused claimed reimbursement for an expense of Php1,810.00, stating that it was incurred at Garden's Cafe in Jagna, Bohol. However, after a field investigation, it was discovered that the actual expense incurred at Garden's Cafe was only Php810.00. The accusation is that the accused falsified the receipt with the intention of causing damage to DKT. The accused argues that the Municipal Circuit Trial Court (MCTC) of Jagna, Bohol does not have jurisdiction over the case because none of the essential elements of the crime were committed in Jagna, Bohol. She contends that the alleged request for reimbursement and the preparation of the document were done in Cebu City, not in Jagna, Bohol. The prosecution, on the other hand, argues that the MCTC of Jagna, Bohol has jurisdiction because the information and complaint-affidavit allege that the crime was committed in Jagna, Bohol. They point to the allegations in the information that the accused falsified a receipt issued by Garden's Cafe in Jagna, Bohol and used it to claim reimbursement.

ISSUES:

1. Whether the crime of falsification of private document falls within the territorial jurisdiction of the Municipal Circuit Trial Court (MCTC) of Jagna, Bohol.

2. Whether the element of damage is necessary in the crime of falsification of private document.

3. Whether the reliance of the Court of Appeals (CA) on the findings of the Regional State Prosecutor and the sworn statement of a witness in another incident was proper in determining the venue of the case.

4. Whether the Court of Appeals (CA) overlooked relevant facts in upholding the finding of improper venue.

5. Whether the CA's reliance on the statement of a witness violates the Rules of Court.

6. Whether the rule on venue should be construed liberally in favor of the accused.

7. Whether there are serious and weighty reasons present to warrant a change of venue.

8. Whether the separate filing of falsification cases in different jurisdictions constitutes multiplicity of actions.

9. Whether Navaja committed a grave procedural error in filing a petition for certiorari from the denial of her motion to quash.

RULING:

1. The crime of falsification of private document falls within the territorial jurisdiction of the Municipal Circuit Trial Court (MCTC) of Jagna, Bohol. The jurisdiction of the court is determined by the allegations of the complaint or information and not by the result of proof.

2. The element of damage is not necessary in the crime of falsification of private document. The court held that mere intent to cause damage is sufficient under Article 172(2) of the Revised Penal Code.

3. The reliance of the Court of Appeals (CA) on the findings of the Regional State Prosecutor and the sworn statement of a witness in another incident was proper in determining the venue of the case. The court found no merit in the contention that venue must be determined solely based on the facts of the instant case and cannot be inferred from other collateral allegations.

4. The CA did not overlook any relevant facts and there is no reason to disturb its factual finding regarding improper venue.

5. The CA's reliance on the witness statement does not violate the Rules of Court as the determination of probable cause only requires the existence of sufficient facts to engender a well-founded belief that a crime has been committed.

6. The rule on venue cannot be construed liberally in favor of the accused in this case, as the multiple charges filed in different jurisdictions were done to prevent harassment and drain the accused's resources.

7. The Court held that the filing of several criminal cases for falsification in different jurisdictions does not constitute a compelling reason to prevent a fair and impartial trial. The Court stated that the MCTC has the power to order a change of venue to avoid a miscarriage of justice, but there must be serious and weighty reasons present. In this case, Navaja failed to prove that such reasons existed. Therefore, the MCTC correctly denied her motion to quash.

8. The Court found that the separate filing of falsification cases in different jurisdictions is consistent with the principle that there are as many acts of falsification as there are documents falsified, and the venue of such cases is where the document was actually falsified. Navaja's argument that this would result in multiplicity of actions was deemed erroneous.

9. The Court held that an order denying a motion to quash is interlocutory and not appealable. However, there are special circumstances where a petition for certiorari may be allowed, such as when the order was issued without or in excess of jurisdiction or with grave abuse of discretion. In this case, Navaja failed to prove any of these special circumstances, thus the Court of Appeals did not err in affirming the RTC ruling that the MCTC correctly denied her motion to quash.

PRINCIPLES:

• The jurisdiction of the court is determined by the allegations of the complaint or information and not by the result of proof.

• Mere intent to cause damage is sufficient in the crime of falsification of private document under Article 172(2) of the Revised Penal Code.

• Venue may be determined based on other collateral allegations and not solely on the facts of the instant case.

• Factual findings of the appellate court are generally conclusive and carry more weight when they affirm the findings of the trial court, unless there is a showing that they are totally devoid of support in the records or are glaringly erroneous.

• TThe determination of probable cause for filing a criminal information requires the existence of sufficient facts to engender a well-founded belief that a crime has been committed, and does not require the same level of evidence as that needed for conviction.

• Improper venue in criminal cases is lack of jurisdiction, and unlike in civil cases, it cannot be waived as it is an essential element of jurisdiction.

• The court has the power to order a change of venue or place of trial to avoid a miscarriage of justice.

• The separate filing of cases for falsification in different jurisdictions is consistent with the principle that there are as many acts of falsification as there are documents falsified and the venue of such cases is where the document was actually falsified.

• An order denying a motion to quash is interlocutory and not appealable. However, there are special circumstances where a petition for certiorari may be allowed, such as when the order was issued without or in excess of jurisdiction or with grave abuse of discretion.