G.R. No. L-2806

FACTS:
The appellants, Balbino Morales et al., were convicted of brigandage under Act No. 518 by the Court of First Instance of Manila. The evidence established that the offense, if committed, occurred in the Provinces of Bulacan and Rizal, with no proof supporting the allegation in the complaint that it was committed in Manila. Appellants Rosauro Sabino, Francisco Primoso, and Romualdo Ramos were arrested in Caloocan, and appellant Balbino Morales was arrested in another municipality, both areas outside Manila. They were brought to Manila for trial. However, appellants Pedro Alapata and Leocadio Reyes were arrested on this complaint while already serving a sentence in Bilibid for a separate offense committed in Manila.

ISSUE:
Whether the Court of First Instance of Manila had jurisdiction to try and sentence the appellants for the crime of brigandage.

RULING:
No, the Court of First Instance of Manila lacked jurisdiction over most appellants. Under Section 3 of Act No. 518 , jurisdiction over brigandage lies in the Court of First Instance of any province where the accused “may be taken or from which they may have fled.” Since the appellants (Sabino, Primoso, Ramos, and Morales) were arrested outside Manila and the crime was not committed there, the Manila court had no jurisdiction. Their convictions were reversed, and they were remanded for trial in a court of proper jurisdiction.

However, the court affirmed the convictions of appellants Alapata and Reyes. As they were lawfully arrested in Manila (while serving a sentence in Bilibid for a Manila crime), the Manila court properly had jurisdiction over them under Section 3 of Act No. 518 . Their guilt was proven beyond reasonable doubt.