G.R. No. L-2733

FACTS:
Nicolas Arceo was charged with the crime of illegal marriage (bigamy). The complaint alleged that on or about May 1, 1901, while still lawfully married to Tranquilina Arcilia, he contracted a second marriage with Teodora de Guia. The documentary evidence established that his first marriage was solemnized on February 3, 1897, in Bacolor, Pampanga. The second marriage was celebrated in the pueblo of Tambobong. At the time of the offense, Tambobong was part of the Province of Rizal, although it was within the 5-mile police jurisdiction of the City of Manila as provided by Act No. 183 . The case was tried by the Court of First Instance of Manila. The defense challenged the court’s jurisdiction over the crime, arguing it was committed outside its territorial jurisdiction.

ISSUE:
Whether or not the Court of First Instance of Manila had jurisdiction to try the case for a crime (bigamy) committed in the pueblo of Tambobong, which was territorially part of the Province of Rizal, even though said pueblo was within the 5-mile police jurisdiction of the City of Manila.

RULING:
No. The Court of First Instance of Manila had no jurisdiction. The Supreme Court set aside the judgment and dismissed the case.

The jurisdiction of courts is fixed by law. Act No. 140 prescribed the territorial jurisdiction of the Courts of First Instance. While Act No. 183 extended the police jurisdiction of the Manila city government to a 5-mile radius, it did not amend Act No. 140 or extend the judicial jurisdiction of the Manila court. A change in judicial territorial jurisdiction cannot be inferred; it must be expressly provided by the legislative body. Since the crime was committed in Tambobong, Province of Rizal, only the Court of First Instance of Rizal had jurisdiction. The proceedings of the Manila court were therefore void. The Court ordered that a new complaint could be filed in the proper court, the Court of First Instance of Rizal.