GR 223833; (December, 2017) (Digest)
G.R. No. 223833 . December 11, 2017.
JOSHUA CASANAS Y CABANTAC A.K.A. JOSHUA GERONIMO Y LOPEZ, PETITIONER, V. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Joshua Casanas was charged with carnapping under Republic Act No. 6539 . The Information alleged that on or about August 12, 2012, in Valenzuela City, he took a Racal motorcycle without the consent of its owner, Christopher Calderon. The prosecution’s evidence established that on August 14, 2012, in Marilao, Bulacan, Calderon allowed Casanas to drive his tricycle (the motorcycle with a sidecar) for a passenger. Casanas failed to return the vehicle. Days later, on August 19, 2012, police officers in Valenzuela City apprehended Casanas in possession of the motorcycle (without the sidecar) and unable to present proof of ownership.
Casanas denied carnapping, claiming he merely borrowed the motorcycle on August 18, 2012, and failed to return it due to a drinking session. He asserted he was apprehended in Valenzuela City while on his way home. The Regional Trial Court (RTC) of Valenzuela City convicted him, a ruling affirmed by the Court of Appeals (CA). Both courts found all elements of carnapping present, noting his failure to return the vehicle and the removal of the sidecar indicated intent to gain.
ISSUE
The primary issue is whether the RTC of Valenzuela City had territorial jurisdiction over the criminal case for carnapping.
RULING
The Supreme Court granted the petition and dismissed the case for lack of jurisdiction. The Court emphasized that jurisdiction over criminal cases is determined by the allegations in the Information and the evidence presented. For jurisdiction to be vested in a court, the offense must have been committed within its territorial jurisdiction.
The Information explicitly alleged the carnapping occurred “in Valenzuela City.” However, the evidence conclusively proved the taking of the motorcycle happened in Marilao, Bulacan, where Calderon entrusted the tricycle to Casanas. His subsequent apprehension in Valenzuela City did not vest jurisdiction there, as the crime of carnapping was consummated upon the unlawful taking in Bulacan. The Court held that a judgment rendered by a court without jurisdiction is void. Consequently, the RTC of Valenzuela City had no authority to try the case. The dismissal is without prejudice to the re-filing of the case before the proper court in Marilao, Bulacan.