Pangilinan v. Court of Appeals
REITERATIONFacts
The Antecedents: Mila G. Pangilinan was charged with Estafa in an information filed on September 20, 1990. The information alleged that on June 15, 1984, in Tanay, Rizal, Pangilinan misrepresented herself to a minor, Luzviminda SJ Elnar, by claiming to be instructed by the minor's father to take a stereo component and other items valued at P17,450.00 for testing, with the intent to permanently deprive the owners, spouses Rolando Elnar and Soledad SJ Elnar, of their property. Procedural History: Pangilinan was arraigned before the Regional Trial Court (RTC) of Morong, Rizal, on March 12, 1991, and pleaded not guilty. The RTC convicted her of Estafa under Article 315 of the Revised Penal Code on October 7, 1991. The Court of Appeals (CA) affirmed the conviction on August 13, 1993, but modified the sentence. A motion for reconsideration was denied, as was a petition for new trial. The Petition: Pangilinan filed a petition for review on certiorari, arguing that the RTC decision was void for lack of jurisdiction over the crime charged and, alternatively, that her guilt was not proven beyond reasonable doubt.
Issue(s)
Whether the Regional Trial Court had jurisdiction over the crime of Estafa as charged in the information. Whether the doctrine of estoppel bars the petitioner from raising the issue of jurisdiction.
Ruling
The petition is GRANTED. The challenged decision of the Court of Appeals is set aside because the Regional Trial Court, whose decision was affirmed therein, had no jurisdiction over Criminal Case No. 0867-M.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the averments in the information determine the crime to be prosecuted and the court that must try it. The information charged Estafa generically, but the RTC presumed it was Estafa under Article 315 of the Revised Penal Code. However, a circumspect examination of the information revealed that it failed to allege all the elements of Estafa under Article 315(1)(b), specifically the demand made by the offended party. The Court noted that the Solicitor General agreed with the Court of Appeals that the information alleged an offense falling under the blanket provision of Article 318 of the Revised Penal Code ("Other Deceits"). A violation of Article 318 is punishable by imprisonment of one (1) month and one (1) day to six (6) months. Under Section 32 of Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980), offenses punishable by imprisonment of not exceeding four (4) years and two (2) months fall within the exclusive original jurisdiction of the Municipal Trial Court, not the Regional Trial Court. Therefore, the RTC lacked jurisdiction over the case from the outset. On the issue of estoppel: The Court rejected the contention that the petitioner was barred from raising the issue of jurisdiction due to estoppel. The Court reiterated the general rule that jurisdiction is vested by law and cannot be conferred or waived by the parties. While the case of Tijam vs. Sibanghanoy established an exception where a party cannot invoke the jurisdiction of a court to secure affirmative relief and then question that same jurisdiction, this doctrine applies when the party seeking recourse in the forum is the one assailing its jurisdiction. In the present case, the petitioner did not invoke the jurisdiction of the RTC in a manner that would lead to estoppel. The Court emphasized that even on appeal, a reviewing court is not precluded from ruling that the lower court had no jurisdiction, especially when the liberty of an individual is at stake. The Court cited People vs. Casiano and People v. Pegarum to support the principle that if a court tries a case without jurisdiction, its proceedings are void, and this can be raised at any stage. The Court also clarified that Section 4, Rule 120 of the Rules of Court, concerning variance between allegation and proof, presupposes that the court rendering judgment has jurisdiction based on the allegations in the information, which was not the case here.
Main Doctrine
A court's jurisdiction is determined by the allegations in the information, not by the evidence presented. If the Regional Trial Court lacks jurisdiction over the offense charged, its decision is void, and the issue of jurisdiction can be raised at any stage of the proceedings, even on appeal, as jurisdiction cannot be conferred by estoppel.