People v. Grospe
REITERATIONFacts
The Antecedents: Respondent-accused, Manuel Parulan, an authorized wholesale dealer of San Miguel Corporation (SMC), issued two checks that were subsequently dishonored for insufficient funds. The first check, dated June 13, 1983, for P86,071.20, was for a prior purchase and was dishonored for insufficient funds. The second check, dated June 18, 1983, for P11,918.80, was for a beer purchase and was also dishonored for insufficient funds. Both checks were issued in favor of SMC. Procedural History: Criminal Case No. 2800 for Violation of B.P. Blg. 22 and Criminal Case No. 2813 for Estafa were filed against Parulan before the Regional Trial Court (RTC) of Pampanga. The RTC, presided over by respondent Judge Nathaniel M. Grospe, dismissed both cases, ruling that it was bereft of jurisdiction to pass judgment because the essential elements of deceit and damage did not occur within its territorial jurisdiction, but rather in Guiguinto, Bulacan, where the checks were issued and delivered, and where the drawee bank was located. The Petition: The People of the Philippines and San Miguel Corporation filed a special civil action for certiorari, seeking to set aside the dismissal order, alleging that the respondent judge committed grave abuse of discretion amounting to lack of jurisdiction.
Issue(s)
Whether the Regional Trial Court of Pampanga has jurisdiction over the criminal cases for Violation of B.P. Blg. 22 and Estafa. Whether the dismissal of the cases for lack of jurisdiction is correctible by certiorari. Whether setting aside the dismissal order would subject the respondent-accused to double jeopardy.
Ruling
The Supreme Court granted the petition, set aside the Decision of the respondent judge, and ordered him to assume jurisdiction over the cases and render judgment based on the evidence presented.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court of Pampanga: The Court held that the venue for transitory offenses, such as estafa by issuing a bad check and violation of B.P. Blg. 22, may be laid in any province where any essential ingredient of the offense took place. For estafa, deceit occurred in San Fernando, Pampanga, where the check was uttered and delivered to the SMC Finance Officer, even though it was received by the SMC Supervisor in Guiguinto, Bulacan. The Court emphasized that delivery to a holder with the intent to transfer title is crucial. For violation of B.P. Blg. 22, while the issuance of the check is a key element, the knowledge of insufficiency of funds is a continuing eventuality, and the venue can also be established where the check was issued or delivered. Furthermore, the allegations in the Information, which stated that the crime was committed in San Fernando, Pampanga, were controlling. On whether the dismissal is correctible by certiorari: The Court ruled that a dismissal based on a perceived lack of jurisdiction, especially when erroneous, is correctible by certiorari. Such an error is considered an error of jurisdiction, not merely an error of judgment, rendering the order void. The petition for certiorari was therefore the proper remedy to correct the respondent judge's grave abuse of discretion. On the issue of double jeopardy: The Court held that the dismissal of the cases was not an adjudication on the merits but a dismissal based on a jurisdictional ground. Since the questioned judgment was not a decision on the merits, it could not bar a subsequent case or continuation of proceedings based on the same offense. Therefore, setting aside the void dismissal order would not subject the respondent-accused to double jeopardy.
Main Doctrine
The venue for transitory offenses, such as estafa by issuing a bad check and violation of B.P. Blg. 22, may be laid in any province where any essential ingredient of the offense took place, including the place where the check was uttered, delivered, or where deceit or damage occurred.