The Supreme Court held that the Metropolitan Trial Court (MeTC) of Manila lacked territorial jurisdiction over a B.P. Blg. 22 case because the prosecution failed to prove that the checks were issued, drawn, delivered, or deposited in Manila. This means that for a court to hear a case involving a bounced check, there must be clear evidence linking the crime’s essential acts (issuance, delivery, deposit) to the court’s specific location. If the prosecution cannot establish this connection, the case must be dismissed, protecting individuals from being tried in a location where the crime did not occur.

Bouncing Checks and Manila Courts: Did the Crime Happen Here?

This case revolves around Raffy Brodeth and Rolan B. Onal, who were charged with violating Batas Pambansa Blg. 22 (B.P. Blg. 22), also known as the Bouncing Checks Law. The charges stemmed from checks issued by Land & Sea Resources Phils. (L&S Resources) to Vill Integrated Transportation Corporation (Vill Integrated) that were dishonored due to insufficient funds. Abraham G. Villegas, the Operations Manager of Vill Integrated, filed an affidavit-complaint, leading to the criminal charges against Brodeth and Onal. The central legal question is whether the Metropolitan Trial Court (MeTC) of Manila had territorial jurisdiction to try the case, given the petitioners’ challenge to the location where the checks were issued.

The petitioners argued that the MeTC lacked jurisdiction because Villegas’ claim that the checks were issued in Manila was unsubstantiated and based on hearsay. They contended that Villegas was not involved in the contractual negotiations and had no direct knowledge of where the checks were issued. The Supreme Court agreed, emphasizing that territorial jurisdiction in criminal cases requires the offense or any of its essential ingredients to have occurred within the court’s territory. This principle is crucial because it ensures that individuals are tried in a location with a direct connection to the alleged crime.

The Court cited Isip v. People, which states that the place where the crime was committed is an essential element of jurisdiction. The ruling underscores that a court cannot take jurisdiction over an offense allegedly committed outside its territory, and if evidence shows the crime occurred elsewhere, the action must be dismissed for lack of jurisdiction. This reinforces the fundamental right of an accused to be tried in the correct venue, ensuring fairness and preventing potential abuse of power by filing cases in locations with no factual basis.

In this case, the lower courts relied heavily on Villegas’ affidavit-complaint, which alleged that the checks were issued in Manila. However, the Supreme Court found this evidence insufficient because Villegas’ role as Operations Manager did not involve direct dealings with clients, making his claim hearsay. This is a critical point because it highlights the importance of firsthand knowledge and reliable evidence in establishing jurisdiction. The Court noted that the phrase “in Manila” appeared only once in the affidavit, casting doubt on the actual place of issuance.

Furthermore, the petitioners claimed that the checks were issued as a guarantee for payments, and Vill Integrated’s liaison officer admitted that payments were typically collected from clients at their respective offices. Considering that L&S Resources’ principal place of business was in Makati City, it would be unusual for the petitioners to travel to Manila to issue the checks. This practical consideration further undermined the prosecution’s claim of Manila as the place of issuance. As the Court held in Morillo v. People, violations of B.P. Blg. 22 are considered transitory or continuing crimes, meaning they can be tried in any location where essential acts, such as issuance, drawing, delivery, or deposit, occurred.

It is well-settled that violations of B.P. [Blg.] 22 cases are categorized as transitory or continuing crimes, meaning that some acts material and essential thereto and requisite in their consummation occur in one municipality or territory, while some occur in another. In such cases, the court wherein any of the crime’s essential and material acts have been committed maintains jurisdiction to try the case.

The Supreme Court emphasized that the prosecution failed to provide evidence linking any of these material acts to Manila. While the allegation was made, no concrete proof supported it, which is insufficient to establish territorial jurisdiction in criminal cases. As such, a mere allegation is not evidence and cannot justify holding someone criminally liable. Therefore, the MeTC lacked a factual basis for its territorial jurisdiction, leading to the dismissal of the case.

FAQs

What was the key issue in this case?	The key issue was whether the Metropolitan Trial Court (MeTC) of Manila had territorial jurisdiction to try the petitioners for violating B.P. Blg. 22, given the lack of evidence that the checks were issued, drawn, delivered, or deposited in Manila.
What is B.P. Blg. 22?	B.P. Blg. 22, also known as the Bouncing Checks Law, penalizes the act of issuing checks without sufficient funds to cover them.
What does territorial jurisdiction mean in criminal cases?	Territorial jurisdiction refers to the court’s authority to hear and decide a case based on where the crime was committed or where any of its essential elements occurred.
Why did the Supreme Court reverse the lower courts’ decisions?	The Supreme Court reversed the decisions because the prosecution failed to prove that any of the essential acts of the crime (issuance, drawing, delivery, or deposit of the checks) occurred within the territorial jurisdiction of the MeTC of Manila.
What evidence did the lower courts rely on to establish jurisdiction?	The lower courts relied on the affidavit-complaint of Abraham G. Villegas, which alleged that the checks were issued in Manila, but the Supreme Court deemed this evidence insufficient and based on hearsay.
What did the petitioners argue in their defense?	The petitioners argued that Villegas’ allegation was unsubstantiated, and they claimed the checks were issued as a guarantee and that payments were usually collected at the client’s office in Makati City.
What is the significance of the Morillo v. People case cited in the decision?	The Morillo v. People case clarifies that violations of B.P. Blg. 22 are transitory or continuing crimes, meaning they can be tried in any location where essential acts, such as issuance, drawing, delivery, or deposit, occurred.
What is the practical implication of this ruling?	The practical implication is that for a court to have jurisdiction over a B.P. Blg. 22 case, there must be concrete evidence linking the crime’s essential acts to the court’s territory. Allegations alone are not sufficient.

In conclusion, the Supreme Court’s decision underscores the importance of establishing territorial jurisdiction with solid evidence in criminal cases, particularly those involving B.P. Blg. 22. This ruling protects individuals from being tried in locations lacking a factual connection to the alleged crime, ensuring fairness and due process in the Philippine legal system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Raffy Brodeth and Rolan B. Onal v. People, G.R. No. 197849, November 29, 2017