G.R. No. L-27590. April 30, 1976.
FELIX O. ALFELOR, SR., ET AL., petitioners, vs. THE HON. BONIFACIO C. INTIA, Municipal Judge, and FELIX A. FUENTEBELLA, respondents.

FACTS

The case originated from the 1965 congressional elections in the second district of Camarines Sur, where respondent Felix A. Fuentebella was proclaimed the winner over petitioner Felix O. Alfelor, Sr. Subsequently, Fuentebella filed a criminal complaint for falsification of public or official documents against Alfelor and the other petitioners. The complaint alleged that the contents of a ballot box from a precinct in Parubcan, Camarines Sur, were falsified. Crucially, the complaint itself admitted that the alleged act of falsification was committed in Iriga, Camarines Sur. Despite this, the complaint was filed in the Municipal Court of Tigaon, Camarines Sur, presided by respondent Judge Bonifacio C. Intia.
The petitioners filed a motion to dismiss on the ground of lack of jurisdiction, arguing that under the Judiciary Act and the Rules of Court, a municipal court’s criminal jurisdiction is confined to offenses committed within its territorial boundaries. Respondent Judge denied the motion, adopting the prosecution’s theory that falsification is a continuing offense. He held that jurisdiction vested in Tigaon because it was one of the municipalities through which the jeepney carrying the allegedly falsified ballot box passed. A motion for reconsideration was likewise denied, prompting the petitioners to file this petition for certiorari and prohibition.

ISSUE

Whether or not the Municipal Court of Tigaon, Camarines Sur, acquired jurisdiction over the falsification case, considering the alleged criminal act was committed in Iriga, Camarines Sur.

RULING

The Supreme Court granted the petition, ruling that the respondent Judge acted without jurisdiction. The legal logic is anchored on two settled principles. First, under Section 86 of the Judiciary Act and Section 14, Rule 110 of the Rules of Court, the jurisdiction of a municipal court in criminal cases is strictly territorial; it extends only to offenses committed within its geographical limits. The place where the crime is committed is not merely a venue requirement but a fundamental element of jurisdiction. Second, the Court definitively rejected the respondent Judge’s characterization of falsification as a continuing offense. Citing a long line of jurisprudence, notably U.S. v. Infante and Lopez v. City Judge, the Court held that the crime of falsification of a document is consummated at the place where the document is actually falsified. The subsequent use, transport, or presentation of the falsified document in another jurisdiction does not extend the crime’s situs or transform it into a continuing offense. Therefore, since the alleged falsification was committed in Iriga, only the court there had territorial jurisdiction. The orders of the respondent Judge were nullified, and he was enjoined from further proceeding except to dismiss the complaint.