Villarosa v. Magallanes
REITERATIONFacts
1. The Antecedents: In the May 12, 1997 elections, petitioner Emilio Villarosa and private respondent Jude Thaddeus Sayson were candidates for barangay captain, with Sayson winning. Other private respondents also won as barangay councilors. Earlier, on May 7, 1997, a complaint was filed against the private respondents for violation of the Omnibus Election Code, alleging the posting of campaign streamers before the campaign period. In their counter-affidavits submitted to the Election Officer in Bacolod City, the private respondents denied this allegation. These counter-affidavits later became the basis for a perjury complaint filed by Villarosa against them, alleging they made untruthful statements under oath, violating Article 183 of the Revised Penal Code. 2. Procedural History: Following a preliminary investigation, eight (8) informations for perjury were filed against the private respondents before the Municipal Trial Court in Cities (MTCC) of Bacolod. The private respondents moved to quash these informations, arguing that jurisdiction lay with the courts in Manila, as their counter-affidavits had been forwarded to the COMELEC Law Department in Manila for preliminary investigation. The MTCC denied this motion. Subsequently, the private respondents filed a petition for certiorari with the Regional Trial Court (RTC) of Negros Occidental, Branch 54. The RTC granted the petition, quashing the informations on the ground of lack of jurisdiction, holding that the Manila court had jurisdiction due to the transmission of the affidavits to COMELEC in Manila. 3. The Petition: This petition for certiorari assails the Resolution of the RTC dated August 3, 1999, which quashed the perjury informations, and the subsequent Order denying the motion for reconsideration. Petitioner argues that the RTC committed grave abuse of discretion. The core issue presented to the Supreme Court is whether jurisdiction over the perjury case lies with the Bacolod court, where the counter-affidavits were executed and initially submitted, or with the Manila court, where they were forwarded for preliminary investigation. Petitioner, supported by the Office of the Solicitor General, contends that jurisdiction is with Bacolod, as the essential ingredients of the offense occurred there. Private respondents argue, citing United States v. Cañet, that jurisdiction lies where the affidavit was presented in a proceeding, which they interpret as Manila due to the transmission for preliminary investigation.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion in quashing the informations for perjury on the ground of lack of jurisdiction, specifically regarding the location where the essential elements of perjury occurred. Whether the Municipal Trial Court in Cities (MTCC) of Bacolod City, rather than courts in Manila, has jurisdiction over the perjury cases filed against the private respondents, considering the submission of counter-affidavits in Bacolod City and their subsequent transmission to Manila.
Ruling
The petition is granted. The resolution of the RTC dated August 3, 1999, and its subsequent order denying the motion for reconsideration are set aside. The orders of the MTCC, Bacolod City, dated July 27, 1998, and September 21, 1998, are reinstated.
Ratio Decidendi
On the RTC's grave abuse of discretion and jurisdiction over perjury cases: The Supreme Court found that the RTC committed grave abuse of discretion amounting to lack of jurisdiction in quashing the informations. The RTC erred in ruling that jurisdiction lay with the Manila courts based on the forwarding of the counter-affidavits for preliminary investigation. The Court clarified that the case of United States v. Cañet, relied upon by the private respondents, was not on all fours with the present case, as it concerned the location of affidavit making versus presentation in court, unlike the present case which concerns submission in an election offense proceeding versus forwarding for preliminary investigation. The Court concluded that the Bacolod courts retained jurisdiction because the essential ingredients of the perjury offense occurred within its territorial jurisdiction. On the jurisdiction over the perjury cases with respect to the MTCC of Bacolod City: The Supreme Court held that the MTCC of Bacolod City has jurisdiction over the perjury cases. The Court reiterated the fundamental principle that a criminal action shall be instituted and tried in the court of the municipality or province where the offense was committed or where any of its essential ingredients took place, as provided in Section 15, Rule 110 of the Rules on Criminal Procedure. In this case, the disputed counter-affidavits containing the alleged false statements were filed by the private respondents with the Office of the Election Officer in Bacolod City, where a complaint for violation of the Omnibus Election Code was lodged against them. The transmission of these affidavits to the COMELEC Law Department in Manila for preliminary investigation did not divest the Bacolod courts of their jurisdiction. The operative acts constituting the crime of perjury, if proven, were committed in Bacolod City, as it was there that the alleged untruthful statements became material in deciding the election offense complaint. The Court emphasized that the lis mota in perjury is the deliberate or intentional giving of false evidence where it is material, and this occurred in the proceeding in Bacolod City. To hold that the Manila court has jurisdiction would lead to judicial anarchy and would be physically and financially burdensome on litigants nationwide, discouraging the prosecution of such offenses.
Main Doctrine
Jurisdiction over the crime of perjury is vested in the court where the affidavit constituting false evidence was filed and where the proceeding for which such evidence was intended was pending, not where the affidavit was subsequently forwarded for preliminary investigation.