GR L 6410; (November, 1954) (Digest)
G.R. No. L-6410 November 24, 1954
JUAN Y. BELTRAN, petitioner, vs. THE HONORABLE EUSEBIO F. RAMOS, ETC., respondent.
FACTS
The petitioner, Juan Y. Beltran, was charged before the Court of First Instance of Occidental Mindoro with the crime of malversation of public funds, alleged to have been committed in San Jose, Occidental Mindoro. The trial commenced in several municipalities within Occidental Mindoro. The continuation of the trial was transferred to Calapan, Oriental Mindoro. Beltran objected to this transfer on the ground that Calapan is outside the territorial boundaries of Occidental Mindoro, the province where the crime was committed. The trial court overruled the objection. Beltran then filed a petition for a writ of prohibition with the Supreme Court to enjoin the trial court from continuing the trial in Calapan.
ISSUE
Whether the trial court may validly continue the trial of a criminal case in a municipality located outside the province where the offense was committed, within a judicial district that comprises multiple provinces.
RULING
No. The Supreme Court granted the petition for prohibition. The Court held that the Rules of Court expressly provide that a criminal case must be instituted and tried in the municipality or province where the offense was committed or where any of its essential ingredients took place. This is a fundamental principle intended to prevent great inconvenience to the accused, such as the hardship of securing witnesses and evidence in a distant location. While the Judiciary Act of 1948 allows a district judge to hold sessions in any province within the judicial district (here, the Eighth Judicial District comprising both Occidental and Oriental Mindoro), this authority must be exercised in harmony with the specific venue rules for criminal cases under the Rules of Court. Transferring the trial to a different province from where the crime was committed would violate these rules and disregard the fundamental rights of the accused. The respondent judge is enjoined from continuing the trial in Calapan, Oriental Mindoro.