G.R. No. L-6992, August 30, 1912
THE UNITED STATES vs. AGUSTIN JUEVES, ET AL.

FACTS

The seven appellants were charged with brigandage under Act No. 518, as amended. The trial court found they participated in a series of criminal acts: (1) On December 31, 1903, in Alabat, Tayabas, a band seized municipal guns and killed a justice of the peace; (2) On February 4, 1904, in Capalohan (then part of Ambos Camarines, later transferred to Tayabas), a band bound prisoners and looted houses; (3) In April 1904, in Basiad, Ambos Camarines, a band took prisoners; and (4) In August 1910, in Calauag, Tayabas, three accused stole rice. Witnesses, including victims and eyewitnesses, positively identified the appellants as participants in these acts. The territory where some acts occurred was transferred from Ambos Camarines to Tayabas before the complaint was filed.

ISSUE

1. Whether the Court of First Instance of Tayabas had jurisdiction to try the case for crimes committed in territory that was part of Ambos Camarines at the time of the acts but was transferred to Tayabas before the filing of the complaint.
2. Whether Section 3 of Act No. 518 is invalid under the Philippine Bill (an ex post facto issue).

RULING

1. Yes, the Court of First Instance of Tayabas had jurisdiction. Jurisdiction is determined by the territorial limits at the time the action is instituted, not at the time the crime was committed. Since the territory was transferred to Tayabas before the complaint was filed, the Tayabas court acquired jurisdiction. This does not violate ex post facto principles, as it merely changes the venue and does not alter the offense or its punishment.
2. The Court did not need to rule on the validity of Section 3 of Act No. 518 because the jurisdictional issue was resolved on other grounds. The change in territorial jurisdiction after the crime but before trial is procedural and does not affect the appellants’ substantive rights.

The convictions were affirmed, with costs against the appellants.