G.R. No. L-32463 July 30, 1982
The People of the Philippines, petitioner, vs. Jose L. Batoy, and The City Court of Oroquieta, Sala 1, respondents.

FACTS

An information was filed against Jose L. Batoy, a former municipal treasurer of Jimenez and Sapang Dalaga, Misamis Occidental, for violation of Article 218 of the Revised Penal Code (Failure of Accountable Officer to Render Accounts). The charge alleged he willfully failed to render his accounts to the Provincial Auditor for periods exceeding two months. The case was filed in the City Court of Oroquieta, the provincial capital where the Provincial Auditor’s office is located.
The accused moved to quash the information, arguing that the City Court of Oroquieta lacked jurisdiction. He contended that since his duties and the source of the accounts were in the municipalities of Jimenez and Sapang Dalaga, the crime was committed there. The City Fiscal opposed, asserting the crime was committed at the office of the Provincial Auditor in Oroquieta, where the accounts were required to be submitted. The City Judge granted the motion and dismissed the case, ruling that the proper venues were the municipal courts of Jimenez and Sapang Dalaga.

ISSUE

Whether the City Court of Oroquieta has jurisdiction to try the case for failure to render accounts under Article 218 of the Revised Penal Code.

RULING

Yes, the City Court of Oroquieta has jurisdiction. The legal logic rests on the proper venue for the crime and the jurisdictional limits of the courts involved. Under Section 14(a), Rule 110 of the Rules of Court, a criminal action shall be instituted and tried in the court of the municipality or province where the offense was committed or where any essential ingredient occurred.
Article 218 penalizes the failure “to render account … to a Provincial Auditor.” The Supreme Court held that this phrase means the account should be rendered at the office of the Provincial Auditor. Consequently, the offense of failure to render is deemed committed at that office, which in this case is located in Oroquieta. Therefore, an essential ingredient of the offense—the failure to submit the accounts at the designated office—took place in Oroquieta, establishing proper venue there.
The Court further clarified that while the municipal courts of Jimenez and Sapang Dalaga could also be potential venues because the accounts originated there, they lacked jurisdiction over the offense. Under the Judiciary Act, municipal judges outside the provincial capital have limited jurisdiction to offenses with a maximum penalty of three years imprisonment or a fine not exceeding P3,000. Article 218 prescribes a penalty of prision correccional in its minimum period or a fine ranging from P200 to P6,000. Since the imposable fine can exceed P3,000, those municipal courts are without jurisdiction. Only the court in the capital, Oroquieta, could try the case. The order of dismissal was reversed and the case remanded for trial.