Casanas y Cabantac v. People, G.R. No.

223833, December 11, 2017

Perlas-Bernabe, J.

Facts:
This case involves a petition for review on certiorari that challenges the
Decision of the Court of Appeals (CA) in CA-G.R. CR No. 35835. These
rulings affirmed the Decision of the Regional Trial Court of Valenzuela City,
Branch 269 (RTC-Valenzuela), finding petitioner Joshua Casanas guilty
beyond reasonable doubt of Carnapping. The case originated from an
Information filed on August 22, 2012, accusing Casanas of unlawfully taking
a Racal motorcycle from its owner, Christopher Calderon. Casanas allegedly
took Christopher Calderon's Racal motorcycle without consent. The
prosecution claimed that Casanas volunteered to drive Calderon's tricycle but
failed to return it, leading Calderon to report the incident the following day.
On August 19, 2012, police officers found Casanas beside the suspected stolen
motorcycle. He couldn't prove ownership, and a knife was discovered in his
possession. Subsequent investigation revealed the motorcycle registered
under Calderon's name. Casanas argued he borrowed the motorcycle,
returning the next day, but was apprehended by police. The RTC-Valenzuela
found him guilty, emphasizing Casanas's failure to return the motorcycle as
agreed. The CA affirmed the decision, highlighting the removal of the sidecar
as evidence of Casanas's intent to appropriate the motorcycle. Casanas's
excuses were dismissed, and his motion for reconsideration was denied,
prompting this petition where Casanas asserts that the RTC-Valenzuela lacked
jurisdiction over the case, contending that the alleged carnapping occurred in
Marilao, Bulacan, not Valenzuela City, Metro Manila, where he was arrested,
charged, and tried. Conversely, the Office of the Solicitor General argues that
Casanas is estopped from challenging the RTC-Valenzuela's jurisdiction, as
he neither sought to quash the Information on this ground nor objected to the
court's jurisdiction, actively participating in the trial instead.

Issue:
Whether or not the RTC-Valenzuela had jurisdiction over the case.

Ruling:

No. The RTC-Valenzuela has no jurisdiction over the case. The Court
underscores that for territorial jurisdiction in criminal cases to be established,
the offense or its essential elements must occur within the court's territory.
While the Information alleges the crime within RTC-Valenzuela's
jurisdiction, evidence, including Calderon's statements, reveals the
carnapping transpired in Marilao, Bulacan. Consequently, the petition asserts
the nullity of the RTC-Valenzuela's conviction due to its lack of jurisdiction,
with the dismissal of the case not barring its re-filing in the proper court in
Marilao, Bulacan. The petition is granted, setting aside the CA's decision and
affirming the dismissal of Criminal Case No. 874-V-12 for jurisdictional
reasons.