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1. People v.

Galacgac

Facts
Enrique Galacgac, a naturalized American citizen was accused of attempted parricide with serious
physical injury alongside with Paulino Galacgac as a consequence of a shooting and beating spree on
November 22, 1951 in Sta. Cruz Manila.
Galacgac claimed that being an American Citizen, he couldn’t be prosecuted and likewise
convicted of illegal possession of firearm since in the United States it is constitutional right “to keep and
bear arms”.

Issue
Whether or not Galacgac was liable for the crimes committed.

Ruling
Yes. The case is open to the application of the general jurisdiction which is to punish persons for
offenses committed within the Philippine territory regardless of the nationality of the offender. A mere
civilian of the U.S Navy is not entitled to any extra territorial privilege for he is not a member of the armed
forces of the United States Army.

2. US v. Sweet

Facts
Sweet, an employee of the United States Army in the Philippines, had assaulted a prisoner of war.
He was charged for the crime of physical injuries with the case filed on the Court of First Instance.
Sweet defensed that being an employee of the U.S military authorities exempts him from the
court’s jurisdiction to give him trial and punishment.

Issue
Whether or not Sweet’s military character exempts him from the ordinary jurisdiction of the civil
tribunals.

Ruling

No. The general principle makes the jurisdiction of the civil tribunals unaffected by the military or
other special character of the person presented before them for trial unless controlled by express
legislation to the contrary.

3. People vs. Livara

Facts
Felipe A. Livara, the provincial disbursing officer of the Philippine Constabulary in Romblon, was
found to have a net shortage on his accountability. The appellant admitted his financial liability but
asserted that he had lost the money in Manila on his way back to Romblon. He was found guilty of
malversation of public funds under the Court of First Instance of Romblon.
Counsel for the appellant contends that the Court of First Instance of Romblon had no jurisdiction
over the case since the alleged crime was done during the incumbency of the accused as an officer of the
Philippine Constabulary.

Issue
Whether or not the Court of First Instance of Romblon has jurisdiction over the case

Ruling
Yes. The accused- appellant had been first tried and convicted of the crime by the Court of First
Instance of Romblon he cannot now claim that the criminal action should have been brought before a
court martial. Civil courts and courts martial have concurrent jurisdiction over offenses committed by a
member of the Armed Forces in violation of a military law and a public law.
4. Arsenia v. Court of Appeals

Facts
Arsenia Garcia, a designated election officer during the 1995 elections, was accused by Aquilino
Pimintel, who ran for a senatorial position, of decreasing the latter’s votes by 5,000 thus violating the
Electoral Reforms Law of 1987. The accused explained that she got fatigued causing the error on the
tabulation of votes, thus invoking the defense of good faith. Pimentel on the other hand argued that the
Electoral Reforms Law is a special law hence it is a malum prohibitum law and therefore, good faith is not
a defense.

Issue
Whether or not the alleged violation of Garcia is a malum prohibitum

Ruling

No. Mala prohibitum refers generally to acts made criminal by special laws, however when the
acts are inherently immoral, they are mala in se even if they are punished under a special law.

The act of decreasing the votes is the one that is being inherently immoral rather than of the
mistakenly decreasing the votes due to fatigue and overload, since it is done with malice and intent to
injure another. Having the violation of the special law as mala in se, the accused can raised in good faith
as a defense. However, the defense of good faith raised by Garcia was not proven.

5. Hector Trenas v. People of the Philippines

Facts

December 22, 1999, to assist in the titling of a house and lot located in Iloilo City, Elizabeth
Luciaja gave Php 150,000.00 to Atty. Hector Trenas. The latter then issued a Deed of Sale with
Assumption of Mortgage and gave three Revenue Official Receipts totaling to Php 120,000.00. These
receipts however were declared by the BIR as fake upon consultation of Luciaja. A case of Estafa was
filed against Hector before the RTC Makati City which rendered a decision finding the petitioner guilty of
the filed case.

Petitioner however claimed that there is no evidence presented by the prosecution that shows
that the 150,000 was given and received by Luciaja in Makati City, same as to the receipts that were
issued. Meanwhile the Deed of Sale with Assumption of Mortgage prepared by the petitioner was
signed and notarized in Iloilo City. Absent of any direct proof as to the place of delivery, Hector asserted
that the RTC of Makati City has no jurisdiction on the controversy.

Issue

Whether or not the RTC of Makati City has the jurisdiction on this case

Ruling

No. Place where the crime is committed is an essential element of jurisdiction. To acquire
jurisdiction by courts in criminal cases, the offense should be committed within the territorial
jurisdiction of the court.

In this case, the prosecution failed to show that the offense of Estafa was committed within the
RTC of Makati’s jurisdiction. There was no documentary evidence offered by the prosecution that points
to where the offense or its elements were committed, thus RTC of the city has no jurisdiction over the
case.
6. Raffy Brodeth et al. vs. People of the Philippines

Facts
Abraham G. Villegas, the operations Manager of Vill Integrated Transportation, transacted with
Land & Sea Resources Phils by providing the latter equipment and tugboats for its operations. However,
two out of three checks which were issued by L & S Resources were dishonored upon being deposited to
Vill Integrated’s account as they were “Drawn Against Insufficient Funds”. L&S Resources not settling their
accounts despite of the demand letters; hence the filing of criminal complaint against petitioners in MeTC
was made.

Raffy Brodeth and Rolan B. Onal asserted that the MeTC has no factual evidence shown that these
checks were either drawn, delivered, or deposited in Manila, thus MeTC has no factual basis for its
jurisdiction.

Issue
Whether or not MeTC has jurisdiction over the case
Ruling
No. From the foregoing, a criminal complaint for violation of B.P Blg 22 may be filed and tried
either at the place where the check was issued, drawn, delivered or deposited. In the present case,
however, evidence on record is missing at any of these material places. In criminal cases, venue or atleast
one of the elements of the crime committed must be proven and not just alleged. The prosecution had
failed to prove such acts, thus they have no territorial jurisdiction in the said case.

7. Manuel Isip v. People of the Philippines

Facts
Accused Manuel S. Isip received some valued jewelries from Leonardo A. Jose in some dates in
February, March and April 1984, for the purpose of selling the same on commission basis and to deliver
the proceeds of the sale thereof or return the jewelry if not sold. However, the accused failed to delivery
of the jewelry and the proceeds despite of the demands of Leonardo A. Jose. The petitioner was charged
with Estafa before the RTC of Cavite City.
Petioner appealed to the CA that none of the essential ingredients of the offenses charged therein
was committed within the jurisdiction of the RTC of Cavite City.

Issues
Whether or not the trial court had jurisdiction over the offense imputed to petitioner and for
which he was convicted.

Ruling
Yes. The venue has been properly laid by the complainant and had sufficiently shown that the
transaction took place in his home in Cavite. The petitioner failed to establish by competent evidence that
the transaction happened in Manila.

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