People v. Taroy
G.R. No. 192466, September 7, 2011


Facts:

Taroy was charged with two counts of rape before the RTC of La Trinidad, Benguet. The RTC found him guilty of the crime charged. Taroy challenged the Benguet RTC’s jurisdiction over the crimes charged, he having testified that their residence when the alleged offenses took place was in Pucsusan Barangay, Baguio City. The RTC held, however, that Taroy’s testimony that their residence was in Baguio City did not strip the court of its jurisdiction since he waived the jurisdictional requirement. The Court of Appeals affirmed the decision of the RTC holding that the prosecution has sufficiently established the jurisdiction of the RTC through the testimony of the witnesses. 


Issue:

Did the RTC of La Trinidad, Benguet have jurisdiction to hear and decide the cases of rape against Taroy?


Held:

"Venue is jurisdictional in criminal cases. It can neither be waived nor subjected to stipulation. The right venue must exist as a matter of law. Thus, for territorial jurisdiction to attach, the criminal action must be instituted and tried in the proper court of the municipality, city, or province where the offense was committed or where any of its essential ingredients took place.

"The Informations filed with the RTC of La Trinidad state that the crimes were committed in the victim and the offender’s house in City Limit, Tuding, Municipality of Itogon, Province of Benguet. This allegation conferred territorial jurisdiction over the subject offenses on the RTC of La Trinidad, Benguet. The testimonies of the witnesses as well as the affidavit of arrest point to this fact. Clearly, Taroy’s uncorroborated assertion that the subject offenses took place in Baguio City is not entitled to belief. Besides, he admitted during the pre-trial in the case that it was the RTC of La Trinidad that had jurisdiction to hear the case. Taken altogether, that RTC’s jurisdiction to hear the case is beyond dispute.