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JOSHUA CASANAS Y CABANTAC v. PEOPLE

FACTS:

Joshua Casanas was charged with the crime of Carnapping for allegedly taking and carrying away a Racal motorcycle without the owner's consent. It was alleged that Casanas volunteered to drive the owner's tricycle for a passenger but failed to return it. The owner reported the incident to the police. A few days later, the police received a report about a suspected stolen motorcycle being sold in Valenzuela City. When the officers responded, they found Casanas standing beside the motorcycle. Casanas was unable to provide proof of ownership. The police frisked him and found a knife in his possession. Casanas, the motorcycle, and the knife were brought to the police station. Further investigation revealed that the motorcycle was registered under the owner's name. Casanas admitted to borrowing the motorcycle but denied stealing it, claiming he was unable to return it due to a drinking session with friends. The RTC-Valenzuela found Casanas guilty, and he appealed the decision to the CA, which affirmed the RTC's ruling. Casanas then filed a petition for review on certiorari to the Supreme Court, arguing that the RTC-Valenzuela had no jurisdiction over the case.

ISSUES:

  1. Whether or not the Regional Trial Court (RTC) had jurisdiction over the case.

  2. Whether or not the information sufficiently alleged the place where the offense was committed.

  3. Whether the Regional Trial Court of Valenzuela City had jurisdiction over the case.

  4. Whether the dismissal of the case would preclude its re-filing in the proper court.

RULING:

  1. No, the RTC did not have jurisdiction over the case. It is a fundamental rule that for jurisdiction to be acquired by courts in criminal cases, the offense should have been committed or any of its essential ingredients should have taken place within the territorial jurisdiction of the court. In this case, the evidence presented by the prosecution, particularly the statements made by the witness, indicate that the crime of Carnapping was committed outside the territorial jurisdiction of the RTC-Valenzuela. Therefore, the case must be dismissed for want of jurisdiction.

  2. No, the information did not sufficiently allege the place where the offense was committed. The information alleged that the crime of Carnapping was committed within the territorial jurisdiction of the RTC-Valenzuela. However, the evidence presented during the trial contradicts this allegation, as it shows that the offense was actually committed in Marilao, Bulacan. The venue and jurisdiction over criminal cases should be placed where the offense was committed or where any of its essential ingredients took place. In this case, the information failed to accurately allege the place where the offense was committed.

  3. The Supreme Court held that the Regional Trial Court of Valenzuela City did not have jurisdiction over the case. The crime of carnapping, including all its elements, did not occur in Valenzuela City, but in Marilao, Bulacan. While the accused was indeed arrested in Valenzuela City, the crime had already been consummated. The unlawful taking of the motor vehicle is deemed complete from the moment the offender gains possession of the thing, even if he has no opportunity to dispose of it. Thus, the judgment convicting the accused is null and void for lack of jurisdiction.

  4. The dismissal of the case does not preclude its re-filing in the proper court. The court emphasized that the dismissal is without prejudice to the re-filing of the same criminal case before the appropriate tribunal, which has territorial jurisdiction over the case, namely, the courts in Marilao, Bulacan.

PRINCIPLES:

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

  • In criminal cases, venue is jurisdictional, and a court cannot exercise jurisdiction over a person charged with an offense committed outside its limited territory.

  • The jurisdiction of a court over a criminal case is determined by the allegations in the complaint or information. However, if the evidence adduced during the trial show that the offense was committed somewhere else, the court should dismiss the action for want of jurisdiction.

  • The venue and jurisdiction over criminal cases shall be placed either where the offense was committed or where any of its essential ingredients took place. The information must sufficiently allege the place where the offense was committed or where any of its essential ingredients occurred.

  • Lack of jurisdiction over the subject matter renders a judgment null and void.

  • A void judgment is devoid of legal effect and cannot bind or bar any party.

  • A void judgment cannot become executory.

  • A void judgment does not constitute a bar to another case by reason of res judicata.

  • Dismissal without prejudice allows the re-filing of the case in the proper court.