G.R. No. L-7969, October 5, 1912
THE UNITED STATES vs. CHUA MO

FACTS

The defendant, Chua Mo, was charged with illegal possession of opium in violation of the Opium Law. The complaint alleged that the offense was committed “on or about the 19th of March, 1912, in the city of Manila, Philippine Islands.” During trial, evidence showed that internal revenue agents found the opium at the defendant’s residence at “717 Calle Sacristia.” However, the record did not explicitly state that Calle Sacristia is located within Manila. The trial court found the defendant guilty and sentenced him to pay a fine. On appeal, the defendant argued that the trial court lacked jurisdiction because the evidence failed to prove the offense was committed within Manila.

ISSUE

Whether the trial court may take judicial notice that a specific street address (717 Calle Sacristia) is located within the city of Manila, thereby establishing jurisdiction over the offense.

RULING

Yes. The Supreme Court affirmed the conviction, holding that the trial court properly took judicial notice under Section 275 of the Code of Procedure in Civil Actions ( Act No. 190 ). This provision allows courts to recognize judicially, without proof, matters of public knowledge such as geographical and political divisions. The Court ruled that cities, municipalities, and their streets are established by public law, and their locations are matters of public record and common knowledge. Citing precedent (Marzon vs. Udtujan) and analogous rulings from U.S. jurisprudence, the Court emphasized that judicial notice extends to the territorial limits of jurisdiction, including the location of streets within a city. Thus, the trial court validly presumed that 717 Calle Sacristia is in Manila, confirming its jurisdiction over the case. The dissent of Justice Trent is noted but did not prevail.