RTC Criminal Case Digest No.

1
G.R. 154557 (February 13, 2008)
People of the Philippines, petitioner,
vs.
The Honorable Court of Appeals, 12
th
Division, Rico Lipao, and Rickson Lipao, respondents.
Facts of the Case:
On October 21, 1991, Rico Lipao and Rickson Lipao were found in possession of 8 pieces of round timbers and 160
bundles of firewood with a market value of Php 3,100.00. Having failed to show the necessary license to transport
the aforementioned forest products, Rico Lipao and Rickson Lipao were accused of violating Section 68 of
Presidential Decree No. 705 as amended by Executive Order No. EO 277. Accordingly, the offense charged is
punishable by Prision Correcional in its medium period is imprisonment from 2 years, 4 months and 1 day up to 4
years and 2 months. While on its maximum, Prision Correcional is imprisonment from 4 years, 2 months and 1 day
up to 6 years. The Surigao City RTC Branch 32 found private respondents guilty beyond reasonable doubt of the
offense charged.
The private respondents appealed to the Court of Appeals. They argued that private respondent Rickson was
subjected to an illegal search and seizure of the round posts and firewood which cannot be used as evidence against
him. Moreover, private respondents argued that the prosecution failed to prove their lack of license to possess
timber. They contended that since private respondent Rico is merely the owner of the pumpboat and was not present
when the posts and firewood were seized, he could never be held liable for illegal possession of timber as he was
never in possession of the round posts.
Amidst the proceedings in this criminal case docketed as Criminal Case No, 551 and before the Surigao City RTC
Branch 32 rendered its judgment, RA 7691. This expanded the exclusive original jurisdiction of MTCs and MCTCs
in criminal cases to cover all offenses punishable with imprisonment not exceeding six years irrespective of the
amount fine. This is the reason why on June 13, 2002, the Court of Appeals granted the appeal of private
respondents and dismissing the case before it on the ground of lack of jurisdiction of RTC despite the fact that the
issue of jurisdiction was never raised by the private respondents.
Issue:
Whether or not the RTC has jurisdiction over the criminal case against private respondents despite the effectivity of
RA 7691.
Ruling:
The petition was granted. The assailed CA decision was revised and set aside. The CA was directed to resolve the
appeal of private respondents on the merits and with dispatch. It has been held as a general rule that the jurisdiction
of a court to try a criminal case is to be determined by the law in force at the time of the institution of the action.
Where a court has already obtained and is exercising jurisdiction over a controversy, its jurisdiction to proceed to the
final determination of the cause is not affected by new legislation placing jurisdiction over such proceedings in
another tribunal. Jurisdiction attached upon the commencement of the action could not be ousted by the passage of
R.A. 7691 reapportioning the jurisdiction of inferior courts, the application of which to criminal cases is, to stress,
prospective in nature. Thus, where private respondents had been charges with illegal logging punishable under
Articles 309 and 310 of the Revised Penal Code, the RTC clearly has jurisdiction at the inception of the criminal
case.
Source: (People of the Philippines vs. The Honorable Court of Appeals, 12th Division, Rico Lipao and Rickson
Lipao, 2008) URL: http://sc.judiciary.gov.ph/jurisprudence/2008/feb2008/154557.htm

RTC Criminal Case No. 2
G.R. No. 192466 (September 7, 2011)
People of the Philippines (Appelle)
Vs.
Alejo Taroy y Tarnate
Facts of the case:
Taroy is the step father of Des whom her mother married in 1997 upon the death of her biological father. Des lived
with his mother, siblings and step father in Pucsusan Barangay, Itogon Benguet.
On August 10, 1997, Des testified that her step father, Taroy raped her while she was alone cleaning their
home. Taroy allegedly warned her that her mother and siblings would suffer harm if she told anyone about it. A year
after, Des testified that Taroy sexually abused her again, pointing a knife against her compelling her to yield to him.
Four years later, on November 1, 2002, she confided what had happened to her aunt and her mom Mila. She
submitted herself to physical examinations which revealed the she has V-shaped indentions over her hymenal edges
that suggest a history of previous blunt force or trauma possibly caused by the insertion of an erect penis. Benguets
RTC convicted him with the evidence that Des camp presented. As a defense, Taroy challenged the jurisdiction of
the said court to try his case. He testified that their residence when the alleged offenses took place was in Pucsusan
Barangay, Baguio City. The RTC held, however, that Taroys testimony that their residence was in Baguio City did
not strip the court of its jurisdiction since he waived the jurisdictional requirement.

Issue:
Whether or not the RTC of LA Trinidad, Benguet has jurisdiction to hear and decide the cases of rape against Taroy.
Ruling:
The court affirmed the decision of RTC and Court of Appeals. It held that the prosecution has sufficiently
established the jurisdiction of the RTC. The information filed with the RTC of La Trinidad state that crimes were
committed in the victim and the offenders house. This allegation conferred territorial jurisdiction over the subject
offenses on RTC of La Trinidad, Benguet. The testimony of Mila and Des as well as the affidavit of arrest point to
this fact. Clearly, Taroys uncorroborated assertion thet he subject offenses took place in Baguio City is not entitled
to belief.. Besides, he admitted during the pre-trial in the case that it was the RTC of La Trinidad that had
jurisdiction to hear the case. Taken together, that RTCs jurisdiction to hear the case is beyond dispute.


Source: (People of the Philippines vs. Alejo Taroy, 2011)
http://sc.judiciary.gov.ph/jurisprudence/2011/september2011/192466.htm






RTC Civil Case No. 1
G.R. No. 145022 (September 23, 2005)
Armand Nocum and The Philippine Daily Inquirer, Petitioners,
Vs.
Lucio Tan, Respondent
Facts of the Case:
On September 27, 1998, Lucio Tan filed before the RTC of Makati, praying for moral and exemplary damages
against Armand Nocum, Capt. Florendo Umali, ALPAP and The Philippine Daily Inquirer for malicious and
defamatory imputations in two news articles of The Philippine Daily Inquirer.
The Inquirer and Nocum, in their joint answer to the complaint, alleged that: a.) there was no cause of action; b.) the
purported defamatory statements were general conclusions without factual premises; c.) the questions news report
constituted fair and true report on the matters of public interest concerning a public figure and therefore, was
privileged in nature and d.) malice on their part was negated by the publication in the same article of plaintiffs or
PALs side of the dispute with pilots union.
ALPAP and Umalo, in their joint answer, alleged that there was also no cause of action, the venue was improperly
laid and Tan was not a real party in interest. It appeared that the complaint failed to state the residence of the
complainant at the time of the alleged commission of the offense and the place where the libelous article was printed
and first published.
At first, the complaint was dismissed for improper venue. But upon a Motion seeking reconsideration of the
dismissal and admission of an amended complaint filed by Tan, the dismissal was set aside by the RTC and admitted
the amended complaint. Aggrieved, Nocum, et al appealed to the CA. CA dismissed their action.

Issue: Whether or not the RTC has acquired jurisdiction over the civil case upon the filing of the original complaint
of damages despite Tans failure to allege the place where the libelous articles were printed and first published.
Ruling:
After examining the original complaint, SC found that the RTC acquired jurisdiction over the case when the case
was filed before it. From the allegations thereof, respondent's cause of action is for damages arising from libel, the
jurisdiction of which is vested with the RTC. Article 360 of RPC, provides that it is RTC that is specifically
designated to try a libel case.

The failure of the original complaint to contain to allege the place where the libelous articles were printed and first
published is not fatal because the case at bar is a civil action where venue is not jurisdictional, unlike in criminal
cases.

Source: (Armand Nocum and The Philippine Daily Inquirer, Inc. vs. Lucio Tan, 2005)
http://sc.judiciary.gov.ph/jurisprudence/2005/sep2005/145022.htm




RTC Civil Case No. 2
G.R. No. 119347 (March 17, 1999)
Eulalia Russell, Puperto Taitho, Francisco Tautho, Susana T. Reales, Apitacio Tautho, Danilo Tautho, Juditha Pros,
Gregorio Tautho, Deodita T. Judilla, Agrapino Tautho, Felix Tautho, William Tautho, and Marilyn Peralea,
petitioners
Vs.
Honorable Augustine A. Vestil, Adriano Tagalog, Marcelo Tautho, Juanita Mendoza, Domingo Bantilan, Raul
Bataluna and Artemio Cabatingan, respondents.
Facts of the Case:
Upon the death of Casimero Tautho and Cesaria Tautho, their land located at Lot 6149, Liloan Cebu was inherited
by their legal heirs, herein petitioners and private respondents. The lot had remained undivided until they discovered
a public document which is a declaration of heirs and deed of confirmation of a previous oral agreement, of
partition, affecting the land executed by and among the respondents whereby respondents divided the property
among themselves to the exclusion of petitioners who are entitled thereto as legal heirs also.
On September 28, 1994, petitioners filed a complaint against private respondents with the RTC of Mandaue City,
Branch 56, docketed as Civil Case No. MAN-2275. They claimed that the document was false and perjurious as the
private respondents were not the only heirs and that no oral partition of the property had been made between the
heirs. The complaint seek to declare the document null and void and an order e issued to partition the land among all
the heirs.
On November 24, 1994, private respondents filed a Motion to Dismiss the complaint on the basis of lack of
jurisdiction of the RTC over the nature of the case as the total assessed value of the land is Php5,000.00 which under
section 33 930 of Batas PAmbansa Blg. 129, as amended by R.A. 7691, falls within the exclusive jurisdiction of the
Municipal Circuit Trial Court of Liloan.
Petitioners filed an Opposition to the Motion to Dismiss saying that the RTC has jurisdiction over the case since the
action is one which is incapable of pecuniary estimation within the contemplation of Section 19(l) of B.P. 129, as
amended.
Issue: Whether or not the RTC has jurisdiction over Civil Case No. MAN-2275
Ruling:
The complaint filed before the RTC is doubtless incapable of pecuniary estimation and therefore within the
jurisdiction of said court. The main purpose of petitioners in filing the complaint is to declare null and void the
document in which private respondents declared themselves as the only heirs of the late spouses Casimero Tautho
and Cesaria Tautho and divided his property among themselves to the exclusion of petitioners who also claim to be
legal heirs and entitled to the property. While the complaint also prays for the partition of the property, this is just
incidental to the main action, which is the declaration of nullity of the document above-described. It is axiomatic
that jurisdiction over the subject matter of a case is conferred by law and is determined by the allegations in the
complaint and the character of the relief sought, irrespective of whether the plaintiff is entitled to all or some of the
claims asserted therein.
Source: (Eulalia Russel vs. Honorable Augustine A. Vestil, 1999)
http://sc.judiciary.gov.ph/jurisprudence/1999/mar99/119347.htm


Sharia Court
G.R. No. 193902 (June 1, 2011)
Atty. Marietta D. Zamoranos, Petitioner
Vs.
People of the Philippines and Samson R. Pacasum, Sr., Respondents
Facts of the case:
On April 28, 1982, Zamoranos converted into Muslim to wed Jesus de Guzman. They got married in Islamic rites on
May 3, 1982. Subsequently, the two wed again, this time, in civil rites before Judge Perfecto Laguio of the RTC,
Quezon City. A little after a year, on December 18, 1983, the obtained a divorce by talaq. The dissolution of their
marriage was confirmed y the Sharia Circuit District Court, 1
st
circuit, 3
rd
district, Isabella, Basilan, which issued a
Decree of Divorce.
On December 18, 1989, Zamoranos married Samson Pacasum under Islamic rites in Balo-I, Lanao del Norte.
Thereafter, on December 29, 1992, to strengthen the rites of their marriage, they renewed their marriage vows in a
civil ceremony before Judge Valerio Salazar of the RTC, Iligan City. Zamaranos and Pacasum were blessed with 3
children, namely: Samson, Sr., Sam Jean and Sam Joon.
Despite their 3 children, the two were de facto separated. This escalated into a battle for custody of their minor
children. However, they arrived at a compromise agreement which vested primary custody to Zamoranos, with
Pacasum retaining visitorial rights. This agreement rankled on Pacasum. He filed a Petition for Annulment of
marriage on March 31, 2003. Subsqeuently, on May 31, 2004, he amended the petition into one for Declaration of a
Void Marriage, alleging that Zamoranos and Pacasums marriage was bigamous and void ab initio because at the
time of their marriage, the former was already previously married to De Guzman.
Issue:
Whether or not the Sharia Court has jurisdiction to grant a divorce decree and thus, give the spouses the right to
remarry.
Ruling:
The Sharia Court has jurisdictioin to grant divorce decree. Spouses who had a divorce under such law is entitled to
remarry other person. Therefore, Zamoranos divorce from De Guzman, as confirmed by an Ustadz and Judge Jainul
of the Sharia Circuit Court, and attested to by Judge Usman, was valid, and, thus, entitled her to marry Pacsasum in
1989. Wherefore, the petition in G.R. No. 193902 is granted. The petition in G.R. 194075 is denied. Accordingly,
the Motion to Quash the Information in Criminal Case No. 06-12305 for Bigamy is granted.
Source: (Atty MArietta D. Zamoranos vs. People of the Philippines and Samson R. Pacasum, 2011)
http://sc.judiciary.gov.ph/jurisprudence/2011/june2011/193902.htm






Supreme Court
G.R. No. 196063 (December 14, 2011)
Orlando A. Rayos, Fe A. Rayos-Dela Paz, represented by Dr. Antonio A. Rayos, and Engr. Manuel A. Rayos,
Petitioners
Vs.
The City of Manila, Respondent
Facts of the case:
The present case originated from a complaint for eminent domain filed by respondent City of Manila against
Remedios V. De Caronongan,et. Al. the City of Manila alleged that it passed Ordinance No. 7949 authorizing the
City Mayor to acquire "by expropriation, negotiation or by any other legal means" the parcel of land co-owned by
defendants, which is covered by TCT No. 227512 and with an area of 1,182.20 square meters. The City of Manila
offered to purchase the property at Php1,000.00 per square meter.
In their Answer, defendants conveyed their willingness to sell the property to the City of Manila, but at the price of
Php50,000.00 per square meter which they claimed was the fair market value of the land at the time.
On 7 December 2009, petitioners Orlando A. Rayos, Fe A. Rayos Dela Paz, and Engr. Manuel A. Rayos filed a
Motion to Dismiss on the grounds that (1) Ordinance No. 7949 is unconstitutional and (2) the cases of Lagcao v.
Labra and Jesus Is Lord Christian School Foundation, Inc. v. Municipality (now City) of Pasig, Metro Manila apply
squarely to the present case.
On 11 March 2010, the trial court denied the motion to dismiss. The trial court ruled that the motion to dismiss did
not show any compelling reason to convince the court that the doctrine of stare decisis applies. Petitioners failed to
demonstrate how or why the facts in this case are similar with the cited cases in order that the issue in this case be
resolved in the same manner.
On 6 January 2011, the trial court denied the motion for reconsideration.
Issue:
Whether or not the petition for review on certiorari and declaratory relief be admitted to the Supreme Court
Ruling:
The petition is denied. An order denying a motion to dismiss is interlocutory and not appealable. An order denying a
motion to dismiss does not finally dispose of the case, and in effect, allows the case to proceed until the final
adjudication thereof by the court.
In all the above instances where the judgment or final order is not appealable, the aggrieved party may file an
appropriate special civil action under Rule 65.
Clearly, no appeal, under Rule 45 of the Rules of Court, may be taken from an interlocutory order. In case of denial
of an interlocutory order, the immediate remedy available to the aggrieved party is to file a special civil action
for certiorari under Rule 65 of the Rules of Court. In this case, since the trial courts order denying the motion to
dismiss is not appealable, petitioners should have filed a petition for certiorari under Rule 65 to assail such order,
and not a petition for review on certiorari under Rule 45 of the Rules of Court. For being a wrong remedy, the
present petition deserves outright dismissal.
This Courts original jurisdiction to issue writs of certiorari is not exclusive. It is shared by this Court with Regional
Trial Courts and with the Court of Appeals. This concurrence of jurisdiction is not, however, to be taken as
according to parties seeking any of the writs an absolute, unrestrained freedom of choice of the court to which
application therefor will be directed. There is after all a hierarchy of courts. That hierarchy is determinative of the
venue of appeals, and also serves as a general determinant of the appropriate forum for petitions for the
extraordinary writs. A becoming regard for that judicial hierarchy most certainly indicates that petitions for the
issuance of extraordinary writs against first level ("inferior") courts should be filed with the Regional Trial Court,
and those against the latter, with the Court of Appeals. A direct invocation of the Supreme Courts original
jurisdiction to issue these writs should be allowed only when there are special and important reasons therefor,
clearly and specifically set out in the petition
Source: (Orlando A. Rayos vs. The City of Manila, 2011)
http://sc.judiciary.gov.ph/jurisprudence/2011/december2011/196063.html