G.R. No. L-20430 May 20, 1965
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. EDUVIGES SAN ANTONIO, defendant-appellee.

FACTS

The prosecution appealed an order from the Court of First Instance of Bulacan that quashed an information for estafa against Eduviges San Antonio. The information alleged that in March 1961, in Obando, Bulacan, the accused, by means of false pretenses, received P2,620.00 from Veronica M. de Leon to buy rice or return the money by May 20, 1961, but instead misappropriated the amount. The accused moved to quash the information, contending the crime was committed outside the trial court’s jurisdiction because a receipt she signed was executed in Manila. The trial court initially denied the motion but later granted a second motion to quash on the same ground and dismissed the case.

ISSUE

Whether the Court of First Instance of Bulacan had jurisdiction over the offense of estafa as alleged in the information.

RULING

Yes. The Supreme Court set aside the order quashing the information and remanded the case. The Court held that for purposes of determining jurisdiction, the allegations in the information control. The information categorically stated the accused received the money in Obando, Bulacan. Furthermore, even assuming the money was delivered in Manila, the accused’s express undertaking, as stated in the information and the receipt, was to deliver the rice or return the money in Obando, Bulacan. The alleged failure to comply with this undertaking—an element of estafa—occurred within the trial court’s jurisdiction.