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Lutgarda Cruz vs. People Case Digest



If the trial court has jurisdiction over the subject matter and over the accused, and the crime was committed within its territorial jurisdiction, it necessarily exercises jurisdiction over all matters that the law requires the court to resolve. This includes the power to order the restitution to the offended party of real property located in another province.


Facts: 

Cruz was charged with the crime of estafa though falsification of public documents before the RTC of Manila. Allegedly, Cruz executed an Affidavit of Self-Adjucation of a parcel of land when she knew that there were other surviving heirs. The offended party did not reserve the right to file a separate civil action. Hence, it was tried together with the criminal case. The RTC acquitted Cruz but on the civil aspect, it court ordered the return of the parcel of land to the surviving heirs. CA upheld the RTC decision.

Petitioner appealed contending that the CA erred in finding that the trial court had jurisdiction to render judgment on the civil aspect of the criminal case. Petitioner asserts that the Manila trial court had no jurisdiction over the parcel of land in Bulacan which is outside the trial court's territorial jurisdiction.


Issue:

Does the RTC of Manila had jurisdiction to render judgment on the civil aspect of the criminal case involving a property in Bulacan?


Held:

Being a civil liability arising from the offense charged, the governing law is the Rules of Criminal Procedure, not the civil procedure rules which pertain to civil action arising from the initiatory pleading that gives rise to the suit.

There are three important requisites which must be present before a court can acquire criminal jurisdiction. First, the court must have jurisdiction over the subject matter. Second, the court must have jurisdiction over the territory where the offense was committed. Third, the court must have jurisdiction over the person of the accused. In the instant case, the trial court had jurisdiction over the subject matter as the law has conferred on the court the power to hear and decide cases involving estafa through falsification of a public document. The trial court also had jurisdiction over the offense charged since the crime was committed within its territorial jurisdiction. The trial court also acquired jurisdiction over the person of accused-petitioner because she voluntarily submitted to the courts authority.

Where the court has jurisdiction over the subject matter and over the person of the accused, and the crime was committed within its territorial jurisdiction, the court necessarily exercises jurisdiction over all issues that the law requires the court to resolve. One of the issues in a criminal case is the civil liability of the accused arising from the crime. Article 100 of the Revised Penal Code provides that [E]very person criminally liable for a felony is also civilly liable. Article 104 of the same Code states that civil liability x x x includes restitution.

The action for recovery of civil liability is deemed instituted in the criminal action unless reserved by the offended party. In the instant case, the offended party did not reserve the civil action and the civil action was deemed instituted in the criminal action. Although the trial court acquitted petitioner of the crime charged, the acquittal, grounded on reasonable doubt, did not extinguish the civil liability. Thus, the Manila trial court had jurisdiction to decide the civil aspect of the instant case - ordering restitution even if the parcel of land is located in Bulacan.

Case remanded for further proceedings. (Lutgarda Cruz vs. People, G.R. No. 123340. August 29, 2002)

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