ATIENZA v.

PEOPLE
GR No. 188694 February 12, 2014

FACTS:
On March 20, 1995, Atibula, a Records Officer and Custodian of the CA Original Decisions,
was invited by petitioner Castro to attend petitioner Atienza’s birthday party. Atienza introduced
Atibula to a certain Dario who later asked Atibula to assist in searching a CA decision.On March 24,
1995, Atibula was asked by Dario to insert a decision in one of the volumes of the CA Original
Decisions but the former refused. On April 21, 1995, Atienza offered Atibula P50000 in exchange for
Volume 260, but the latter turned down the offer. Volume 266 was later discovered to be missing
on May 9, 1995. Atibula encountered Atienza two days later, with the former shouting: “putang ina
mo, Juaning, pinaharapan mo kami”. The volume was later returned on May 18, 1995 by Nelson de
Castro, claiming Castro asked him to deliver the volume to Atibula. Upon inspection by Atibula, the
returned volume had two new documents inserted. Upon further inspection, the documents did not
bear the original promulgations. Upon analysis and examination by NBI, it was concluded that
Volume 266 was indeed altered, and that the signatures of the CA Justices in the questioned
documents were forgeries. Sometime in July 1995, a wall in the CA Reporter’s Division was
discovered to be broken. Upon investigation, it was concluded by the NBI that perpetrators gained
entry to the office through the wall, and there was conspiracy to commit the crime of Falsification of
Public Document between Atienza and Dario in view of their concerted efforts through previous or
simultaneous acts and deeds. It was also added that Castro assisted the suspects in the crime by
returning the missing volume.
Atienza, Castro and Dario were later charged before the Office of the Ombudsman for the
following crimes: Falsification of Public Document, violation of Sec. 3(a) of RA No. 3019, and
violation of Sec. 8 of RA No. 6713. The latter two charges were dismissed for insufficiency of
evidence but it was ruled that there existed a probable cause to charge them for Robbery under Art.
299(a)(1) of the RPC, and Falsification of Public Document under Art. 172(1) in relation to Art.
171(6) of the same code. The Informations were later docketed before the RTC. The RTC ruled that
the petitioners are guilty beyond reasonable doubt for the crimes charged against them. For the
crime of Falsification of Public Document, they were sentenced to suffer a penalty of 6 months and
1 day, as minimum, to 6 years of prision correccional as maximum. The CA affirmed the conviction
of the petitioners upon appeal, and also denied their motion for reconsideration.
Hence, the instant petition before the Court, in which the petitioners also raised that there is
jurisdictional defect for their Falsification case.

ISSUE:
Whether or not there was a jurisdictional defect for the falsification case.

RULING:
YES. Sec. 32 of BP Blg. 129, otherwise known as the Judiciary Reorganization Act of 1980, as
amended by RA No. 7691, provides that Metropolitan Trial Courts, Municipal Trial Courts, and
Municipal Circuit Trial Courts shall have exclusive original jurisdiction over all offenses punishable
with imprisonment not exceeding six years. Falsification of Public Document under Art. 172(1) of
the RPC is punishable by prision correccional in its medium and maximum periods or
imprisonment for 2 years, 4 months and 1 day to 6 years.
In the case at bar, the RTC should not have jurisdiction to take the Falsification case because
the MTC, MeTC, and MCTC have exclusive original jurisdiction over the case because the offense is
punishable with imprisonment of not exceeding 6 years.

NOTE:
Lack of jurisdiction over the subject matter may be raised at any stage of the proceedings