3.

Cariaga vs People
Facts: Petitioner Cenita M. Cariaga is a municipal treasurer of Cabatuan, Isabela whose been charged with
three separate cases before the Regional Trial Court of Isabela, all for malversation of public funds. Cariaga
was convicted for the said cases. Hence, an appeal was filed before the Court of Appeals.

The Court of Appeals dismissed petitioners appeal for lack of jurisdiction, holding that it is the
Sandiganbayan which has exclusive appellate jurisdiction thereon. Petitioner, admitting the procedural
error committed by her former counsel, implores the Court to relax the Rules to afford her an opportunity
to fully ventilate her appeal on the merits and requests the Court to endorse and transmit the records of
the cases to the Sandiganbayan in the interest of substantial justice.

Issue: W/N the appeal of Cariaga wrongfully directed to the court of appeals be dismissed outright or be
endorsed and transmitted to the Sandiganbayan where the appeal shall then proceed in due course.

Ruling: No. Let the records of the cases be FORWARDED to the Sandiganbayan for proper disposition.
Since the appeal involves criminal cases, and the possibility of a person being deprived of liberty due to a
procedural lapse militates against the Courts dispensation of justice, the Court grants petitioners plea for a
relaxation of the Rules.

For rules of procedure must be viewed as tools to facilitate the attainment of justice, such that any rigid
and strict application thereof which results in technicalities tending to frustrate substantial justice must
always be avoided.

4. Lutgarda Cruz v. Court of Appeals, People of the PH, and the Heirs of Estanislawa Reyes, 388 SCRA 72
Facts: Petitioner maintains that the Court of Appeals erred in finding that the trial court had jurisdiction to
render judgment on the civil aspect of the criminal case. Petitioner asserts that the Manila trial court had
no jurisdiction over the parcel of land in Bulacan which is outside the trial court’s territorial jurisdiction.
The CA held: "Being a civil liability arising from the offense charged, the governing law is the Rules of
Criminal Procedure, not the civil procedure rules which pertain to civil action arising from the initiatory
pleading that gives rise to the suit."

Issue: W/N the RTC of Manila had jurisdiction to render judgment on the civil aspect of criminal case for
falsification of public document involving a property located in Bulacan.

Ruling: Yes.
Petitioner asserts that the location of the subject property outside the court’s territorial jurisdiction
deprived the trial court of jurisdiction over the civil aspect of the criminal case. This argument is contrary to
the law and the rules.

There are three important requisites which must be present before a court can acquire criminal
jurisdiction. First, the court must have jurisdiction over the subject matter. Second, the court must have
jurisdiction over the territory where the offense was committed. Third, the court must have jurisdiction
over the person of the accused.

In the instant case, the trial court had jurisdiction over the subject matter as the law has conferred on the
court the power to hear and decide cases involving estafa through falsification of a public document. The
trial court also had jurisdiction over the offense charged since the crime was committed within its
territorial jurisdiction. The trial court also acquired jurisdiction over the person of accused-petitioner
because she voluntarily submitted to the court’s authority.1âwphi1

Where the court has jurisdiction over the subject matter and over the person of the accused, and the crime
was committed within its territorial jurisdiction, the court necessarily exercises jurisdiction over all issues
that the law requires the court to resolve. One of the issues in a criminal case is the civil liability of the
accused arising from the crime. Article 100 of the Revised Penal Code provides that "[E]very person
criminally liable for a felony is also civilly liable." Article 104 of the same Code states that "civil liability x x x
includes restitution."
MP: A reading of jurisprudence and treatises on the matter discloses the following basic requisites before a
court can acquire jurisdiction over criminal cases:
(a) Jurisdiction over the subject matter;
(b) Jurisdiction over the territory; and
(c) Jurisdiction over the person of the accused.