GR 197849; (November, 2017) (Digest)
G.R. No. 197849 November 29, 2017
RAFFY BRODETH and ROLAN B. ONAL, Petitioners vs. PEOPLE OF THE PHILIPPINES and ABRAHAM G. VILLEGAS, Respondents
FACTS
Petitioners Raffy Brodeth and Rolan B. Onal were charged before the Metropolitan Trial Court (MeTC) of Manila with two counts of violating Batas Pambansa Blg. 22 (B.P. 22). The informations alleged that they issued Metrobank checks to Vill Integrated Transport Corporation, represented by Abraham Villegas, which were subsequently dishonored for having been drawn against insufficient funds. The prosecution presented the dishonored checks and demand letters. Petitioners, in defense, argued that the obligations represented by the checks had been settled in cash and that the obligation was personal to another individual, Noli Dela Cerna. The MeTC convicted petitioners, a ruling affirmed by the Regional Trial Court and the Court of Appeals.
ISSUE
Whether the MeTC of Manila validly acquired territorial jurisdiction over the criminal cases for violation of B.P. 22.
RULING
The Supreme Court REVERSED the assailed rulings and DISMISSED the criminal cases for lack of jurisdiction. The Court held that for B.P. 22 cases, jurisdiction is vested in the court of the place where any of the essential elements of the offense occurred, specifically where the check was drawn, issued, delivered, or dishonored. The prosecution bears the burden of proving this venue by competent evidence. In this case, the only link to Manila was the allegation in the informations that the checks were issued there. The prosecution failed to present any evidence, such as testimony or documentation, to substantiate that the acts of drawing, issuing, or delivering the checks transpired in Manila. The dishonor occurred at the drawee bank, whose location was not established to be in Manila. An allegation in an information is not proof. Since the prosecution did not establish that any element of the offense was committed within the territorial jurisdiction of the MeTC of Manila, said court had no authority to try the case. The dismissal is without prejudice to refiling in the proper venue.