Raffy Brodeth & Rolan B. Onal vs. People of the Philippines & Abraham G. Villegas

G.R. No. 197849, November 29, 2017; per Martires, J.

Facts

Private complainant Abraham G. Villegas alleged in an information against petitioners that in the course of his company's operations, he transacted with Land & Sea Resources Phils. (L&S Resources), Inc. by providing the latter equipment and tugboats for its own operations. Among the payments made by L&S Resources were three checks drawn against Metropolitan Bank and Trust Company (Metrobank). Two out of these three checks, particularly: (a) Metrobank Check No. 2700111415 dated 31 August 1999, and (b) Metrobank Check No. 2700111416 dated 5 September 1999,7 are the subject checks in the instant case. When the subject checks were deposited to Vill Integrated's account, they were dishonored as they were "Drawn Against Insufficient Funds (DAIF)."

The Metropolitan Trial Court, Branch 30A Manila (MeTC) found petitioners guilty beyond reasonable doubt for violation of B.P. Blg. 22. The MeTC held that the dishonor of the subject checks was sufficiently shown by the letters "DAIF" written at the back of the checks, which is prima facie evidence that the drawee bank had dishonored the checks. Moreover, the MeTC ruled that petitioners had known the checks were dishonored because they admitted they had the demand letters.

Issue

Whether or not the Metropolitan Trial Court Branch 30A Manila had jurisdiction over the case when there was doubt that the subject checks were issued within Manila

Ruling

The Supreme Court ruled that since the prosecution failed to prove that the subject checks were issued in Manila nor was any evidence shown that these were either drawn, delivered, or deposited in Manila, the MeTC has no factual basis for its territorial jurisdiction.

A court cannot take jurisdiction over a person charged with an offense allegedly committed outside of that limited territory, and if the evidence adduced during trial shows that the offense was committed somewhere else, the court should dismiss the action for want of jurisdiction.