GR L 25795; (October, 1966) (Digest)
G.R. No. L-25795 October 29, 1966
ANGELINA MEJIA LOPEZ, AURORA MEJIA VILLASOR, ROY P. VILLASOR, petitioners, vs. THE CITY JUDGE, CESAR L. PARAS, TRINIDAD T. LAZATIN, and TERRA DEVELOPMENT CORPORATION, respondents.
FACTS
In February 1964, petitioners, as heirs and administrator of the intestate estate of spouses Manuel M. Mejia and Gloria Lazatin, entered into a contract with respondent Trinidad T. Lazatin for the development and subdivision of estate lands. Lazatin later assigned his rights to Terra Development Corporation. Subsequently, petitioners filed an action for rescission of the contract in the Court of First Instance of Quezon City. In turn, Lazatin and the corporation filed a complaint with the City Fiscal of Angeles, leading to the filing of an information in the City Court of Angeles (Criminal Case No. C-2268) charging petitioners with falsification of a private document under Article 172 of the Revised Penal Code. The information alleged that petitioners falsely stated in the contract that Aurora M. Villasor and Angelina M. Lopez were the “guardians” of their minor brothers, when they knew the judicial guardian was another person. Petitioners moved to dismiss, and later filed a motion to quash, on the ground that the City Court of Angeles lacked jurisdiction because the document was signed by them outside its territorial limits—specifically, within Makati and Quezon City, both in Rizal. The respondent judge denied the motion to quash. Petitioners then filed this action for certiorari and prohibition.
ISSUE
Whether the City Court of Angeles City has jurisdiction to try and decide Criminal Case No. C-2268 for alleged falsification of a private document.
RULING
No. The City Court of Angeles City has no jurisdiction over the offense charged. The crime of falsification of a private document is consummated at the time and place where the document is actually falsified with the intent to prejudice a third person, regardless of whether the falsified document is later put to illegal use. The record shows that the private document was signed by the petitioners outside the territorial jurisdiction of Angeles City—specifically in Makati and Quezon City. Therefore, the act of falsification, if any, was committed and consummated beyond the territorial jurisdiction of the City Court of Angeles. The subsequent use of the document within Angeles City is not a material element of the crime of falsification. The writs of certiorari and prohibition are granted to prevent a void proceeding and to avoid the unfairness and mental anguish of a trial in a court without jurisdiction. The City Court of Angeles is restrained and prohibited from further proceedings in Criminal Case No. C-2268.