Ricardo L. Atienza and Alfredo A. Castro vs. People of the Philippines

G.R. No. 188694, February 12, 2014; per Perlas-Bernabe, J.

Facts

On March 20, 1995, Juanito Atibula (Atibula), Records Officer I was invited by Castro to attend Atienza’s birthday party and there introduced Atibula to a certain Dario and asked him to assist the latter in searching for the CA decision in the case entitled "Mateo Fernando v. Heirs of D. Tuason, Inc." (Fernando), docketed as CA-G.R. No. 36808-R.

Several days after, Dario requested Atibula to insert a Decision dated September 26, 1968 in one of the volumes of the CA Original Decisions but the latter refused. Consequently, the latter was offered ₱50,000.00 in exchange for Volume 260, which the latter turned down and reported the incident to Atty. Arnel Macapagal who then instructed him (Atibula) to hide Volumes 260, 265 and 267 in a safe place.

On May 9, 1995, Atibula discovered that Volume 266 was missing. On May 18, 1995, a certain Nelson de Castro handed to Atibula a bag containing a gift-wrapped package which turned out to be the missing Volume 266. He claimed that it was Castro who asked him to deliver the said package to Atibula but noticed that there were two new documents inserted therein.

Issue

Whether or Not the RTC has jurisdiction over the falsification case

Ruling

The Supreme Court ruled that the RTC did not have jurisdiction to take cognizance of Criminal Case No. 01-197426 (i.e., the falsification case) since Falsification of Public Document under Article 172(1) of the RPC, which is punishable by prision correccional in its medium and maximum periods (or imprisonment for 2 years, 4 months and 1 day to 6 years) and a fine of not more than ₱5,000.00, falls within the exclusive jurisdiction of the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts pursuant to Section 32(2) of Batas Pambansa Bilang 129, otherwise known as the "Judiciary Reorganization Act of 1980," as amended by RA 7691.