Angelina Mejia Lopez, et al. vs. Cesar L. Paras, et al.

G.R. No. L-25795, October 29, 1966; per Dizon, J.

Facts

Herein petitioners entered into a contract with respondent Trinidad T. Lazatin for the development and subdivision of three parcels of land belonging to said intestate estate. Months later, petitioners and other co-heirs filed an action in the Court of First Instance of Quezon City for the rescission of said contract for alleged gross and willful violation of its terms.

Upon petition of the parties thus charged, the City Fiscal of Angeles reinvestigated the case giving them an opportunity to present exculpatory evidence. The parties charged moved for the dismissal of the case mainly on the ground that the City Court of Angeles had no jurisdiction over the offense because the private document that contained the alleged false statement of fact was signed by them outside the territorial limits of said city.

In view of the City Fiscal's continued failure to act on the motion to dismiss the case, petitioners filed a motion to quash upon the ground that said court had no jurisdiction over the offense charged. The complainants in the case — with the conformity of the City Fiscal — filed an opposition thereto, and on February 3, 1966 the respondent judge denied said motion to quash. In view thereof, petitioners filed the present action for certiorari and prohibition.

Issue

Whether the City Court of Angeles has jurisdiction to try and decide the case

Ruling

The Supreme Court ruled that the City Court of Angeles has no jurisdiction over the criminal act, but the importance of this case is when and where a falsification of document comes in. As ruled clearly and definitely in U.S. vs. Infante, 36 Phil. 146, the crime of falsification of a private document is consummated when such document is actually falsified with the intent to prejudice a third person, whether such falsified document is or is not thereafter put to the illegal use for which it was intended. It is settled law in criminal actions that the place where the criminal offense was committed not only determines the venue of the action but is an essential element of jurisdiction.