DIGESTED CASES FOR CRIMINAL PROCEDURE

Mula, Iane Gem M. , JD 2-2

------------------------------------------------------------------------------------------------------------------------------------------

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler: This case talks about how the place where the crime was committed determines not only the venue
of the action but is an essential element of jurisdiction.

Doctrine: Jurisdiction of the court is determined by the allegations of the complaint or information and once
shown, the court may validly take cognizance of the case;

How jurisdiction attaches; The place where the crime was committed determines not only the venue of the
action but is an essential element of jurisdiction.

Case Title:
ANA LOU B. NAVAJA v. MANUEL A. DE CASTRO +
GR No. 182926, Jun 22, 2015
PERALTA, J.

Facts:

The case arose from a complaint filed by private respondent DKT Philippines, Inc. Represented by
Atty. Edgar Borje against petitioner Ana Lou Narvaja, alleging that while she was still its Regional Sales
Manager, she falsified a receipt by making it appear that she incurred meal expenses for P1,810.00 instead
of the actual amount of P810.00 at Garden Café, Jagna, Bohol, and claimed reimbursement for it. She was
charged with falsification of private document before the MCTC of Jagna Bohol.

Narvaja filed a motion to quash/defer arraignment on the ground that none of the essential
elements of the crime of falsification of private document occurred in Jagna, Bohol, hence, MCTC had no
jurisdiction to take cognizance of the case due to improper venue. MCTC denied the motion to quash. She
then filed a motion for reconsideration which was also denied.

She then filed a petition for certiorari before RTC for having been issued with grave abuse of
discretion. The court denied it for lack of legal basis or merit and that there were sufficient evidences
indicating that the falsification took place in Jagna Bohol. If the court were to follow the logic of the petition,
her claim that her request for reimbursement was made in Cebu City not in Jagna, Bohol would likewise
give no showing or indication that the falsification was done in Cebu. It would result to a “neither here nor
there” situation.

Narvaja elevated the case on appeal to the CA and was also dismissed, affirming in toto the decision
of the RTC. Her motion for reconsideration was likewise denied. Hence, this petition for review on certiorari.

Issue: WON the MCTC of Jagna, Bohol does not have jurisdiction over the criminal case and WON there was
an improper venue

Ruling:

No. Venue in criminal cases is an essential element of jurisdiction. Under the Revised Rules of
Criminal Procedure, the criminal action shall be instituted and tried in the court or municipality or territory
where the offense was committed or where any of its essential ingredients occurred. Based on the
allegations of the complaint, the falsification of private document was actually committed in Jagna, Bohol.

Guided by the settled ruled that the jurisdiction of the court is determined by the allegations of the
complaint or information and not by the result of proof, the court holds that Narvaja’s case falls within the
territorial jurisdiction of Jagna, Bohol.

---0---

Tickler: This case is about how jurisdiction in a criminal action is conferred, particularly criminal actions
arising from violations of P.D. 957 otherwise known as The Subdivision and Condominium Buyers' Protective
Decree.

Doctrine: Jurisdiction of the Court in Criminal Cases; Jurisdiction is conferred by law; Jurisdiction over
criminal actions arising from violations of PD 957 is vested in the regular courts.

Case Title:
MA. LUISA G. DAZON, PETITIONER, VS. KENNETH Y. YAP AND PEOPLE OF THE PHILIPPINES, RESPONDENTS
GR No. 157095, Jan 15, 2010
DEL CASTILLO, J.

Facts:

Respondent Kenneth Yap was the president of Primetown Property Group, developer of Kiener
Hills Mactan Condominium, a low-rise condominium project. Petitioner made a down payment with
Primetown for purchase of a unit as well as several installments payments totalling to P1Million plus.
Primetown however failed to finish the condominium project. Dazon demanded the refund of her
payments from Primetown, pursuant to P.D. 957 otherwise known as the Subdivision and Condominium
Buyers' Protective Decree.

She then filed a criminal complaint with the office of the City Prosecutor of Lapu-Lapu City for
violation of P.D. 957. Subsequently, after finding probabble cause, an information was filed with RTC of
Lapu-Lapu. Meanwhile, Yap filed a petition for review with the Department of Justice wherein the trial
prosecutor ordered to cause the withdrawal of the information. Hence, the prosecutor file a motion to
withdraw information with the RTC. It was granted by the court and Dazon’s motion for reconsideration
was denied.

Issue: WON RTC has jurisdiction over a criminal action arising from P.D. 957 and not HLURB

Ruling:

Yes. Jurisdiction is conferred by law and that there is no law expressly vesting on the Housing and
Land Regulatory Board exclusive jurisdiction over criminal actions arising from violations under P.D. 957.
Not having been specifically conferred with power to hear and decide cases which are criminal in nature,
as well as to impose penalties, HLURB had no jurisdiction over the case.

Sec. 20 of B.P. 129 vests to RTC exclusive original jurisdiction in all criminal cases not within the
exclusive jurisdiction of any court, tribunal or body except those falling under the exclusive and concurrent
jurisdiction of the Sandiganbayan.

Hence, it is the RTC of Lapu-Lapu that has jurisdiction to hear and decide on the case.

---0---
Tickler: This case talks about how criminal actions are instituted, particularly those cases referred to in Rule
110 (b) of the Revised Rules of Criminal Procedure.

Doctrine: As a general rule, a criminal action is commenced by a complaint or information, both of which
are filed in court. If a complaint is filed directly in court, the same must be filed by the offended party and in
case of an information, the same must be filed by the fiscal. However, a complaint filed with the fiscal prior
to a judicial action may be filed by any person.

Case Title:
JORGE SALAZAR, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent

G.R. No. 149472. October 15, 2002

PUNO, J.

Facts:

The accused received from Olivier Philippines and Skiva International, Inc. the amount of
$41,300.00 for the sole purpose of meeting the cost of textile and labor in the manufacture of seven
hundred dozen stretch twill jeans which he (accused) is duty bound to deliver to said complainant, and the
accused once in possession of the same, far from complying from his obligation, with unfaithfulness and
abuse of confidence and to defraud said complainant, did, then and there willfully and unlawfully and
feloniously misappropriate, misapply and convert the same for his own personal use and benefit despite
repeated demands to return the said amount, failed and refused and still fails and refuses to do so, to the
damage and prejudice of said complainant, in the aforementioned amount of $41,300.00or its equivalent
in Philippine currency.

Issue: WON it is necessary that the proper offended party file a complaint for purposes of preliminary
investigation by the fiscal

Ruling:

No. It is not necessary that the proper “offended party” file a complaint for purposes of preliminary
investigation by the fiscal—a “complaint” filed with the fiscal prior to a judicial action may be filed by any
person; If a complaint is filed directly in court, the same must be filed by the offended party and in case of
an information, the same must be filed by the fiscal.—The “complaint” referred to in Rule 110 contemplates
one that is filed in court to commence a criminal action in those cases where a complaint of the offended
party is required by law, instead of an information which is generally filed by a fiscal. It is not necessary that
the proper “offended party” file a complaint for purposes of preliminary investigation by the fiscal. The rule
is that unless the offense subject of the complaint is one that cannot be prosecuted de oficio, any
competent person may file a complaint for preliminary investigation. Thus, as a general rule, a criminal
action is commenced by a complaint or information, both of which are filed in court. If a complaint is filed
directly in court, the same must be filed by the offended party and in case of an information, the same
must be filed by the fiscal. However, a “complaint” filed with the fiscal prior to a judicial action may be filed
by any person. Thus, in the case at bar, the complaint was validly filed by Skiva despite the finding of the
lower court that petitioner had no obligation to account to Skiva.

---0---

Tickler: This case covers the effects of the institution of a criminal action particularly stated in Rule 110,
Section 1 (b) of the Revised Rules of Criminal Procedure and that there is no more distinction between cases
under the RPC and those covered by special laws with respect to the interruption of the period of
prescription.

Doctrine: The institution of the criminal action shall interrupt the running of the period of prescription of the
offense charged unless otherwise provided in special laws.

It is the institution of criminal actions, whether filed with the court or with the Office of the City Prosecutor,
that interrupts the period of prescription of the offense charged.

Case Title:
PEOPLE v. MA. THERESA PANGILINAN +
GR No. 152662, Jun 13, 2012
PEREZ, J.

Facts:

On 16 September 1997, Virginia C. Malolos filed an affidavit-complaint for estafa and violation of Batas
Pambansa (BP) Blg. 22 against Ma. Theresa Pangilinan (respondent) with the Office of the City Prosecutor
of Quezon City. The complaint alleges that respondent issued nine (9) checks with an aggregate amount
of Nine Million Six Hundred Fifty-Eight Thousand Five Hundred Ninety-Two Pesos (P9,658,592.00) in favor
of private complainant which were dishonored upon presentment for payment.

Consequently, the case was modified, and only on February 3, 2000 that two counts for violation of BP Blg.
22 were filed against respondent Ma.Theresa Pangilinan in the Metropolitan Trial Court of Quezon City. On
17 June 2000, respondent filed an “Omnibus Motion to Quash the Information and to Defer the Issuance
of Warrant of Arrest” before MeTC, Branch 31, Quezon City. She alleged that her criminal liability has been
extinguished by reason of prescription.

In defense of her claim, Pangilinan said that the prevailing law that governs the prescription of special penal
law, B.P. 22, is Section 2 of Act No. 3326 (An Act To Establish Periods Of Prescription For Violations Penalized
By Special Acts) where the right to file an action to a “proper court” and not to merely to prosecution office
for B.P. 22, prescribes four (4) years from the commission of the crime. The imputed violation occurred
sometime in 1995, and only on February 3, 2000 that a case was formally filed in the Metropolitan Trial
Court, therefore the action already prescribes. RTC granted the motion.

On the other hand, the complainant argued that the filing with the office of city prosecutor constitutes an
interruption to the prescription.
Issue: Is filing complaint to city prosecutor office considered a “judicial proceeding” that can interrupt
prescription of crime under B.P. 22, a special law?

Ruling:

YES. Following a catena of cases, the court held that, there is no more distinction between cases under the
Revised Penal Code (RPC) and those covered by special laws with respect to the interruption of the period
of prescription; that the institution of proceedings for preliminary investigation in the office of prosecutor
against accused interrupts the period of prescription.

Following the factual finding the crime was committed sometime in 1995, the filing of complaint on
September 1997, two (2) years from the commission of the crime validly interrupts the running of
prescription. Therefore, the action against the respondent Pangilinan did not prescribe.

---0---

Tickler: This case speaks about the definition of information as stated in Rule 110 Section 2 and its being the
same with or considered as a pleading.

Doctrine: Rule 110, an information is defined as an accusation in writing charging a person with an offense,
subscribed by the prosecutor and filed with the court.

In accordance with the above definition, it is clear that an information is a pleading since the allegations
therein, which charge a person with an offense, is basically the same as a complaint in a civil action which
alleges a plaintiff's cause or cause of action.

Case Title:
PEOPLE v. JESUS A. ARROJADO +
GR No. 207041, Nov 09, 2015
PERALTA, J.

Facts:

Jesus Arrojado, charged with Murder in an Information filed by the Office of the City Prosecutor of Roxas
City, filed a Motion to Dismiss the Information against him on the ground that the investigating prosecutor
who filed the Information did not indicate therein the number and date of issue of her Mandatory
Continuing Legal Education Certificate of Compliace, as required by Bar Matter No. 1922 promulgated by
the Court on June 3, 2008. The Office of the City Prosecutor opposed the Motion to Dismiss, contending
that 1) the Information sought to be dismissed is sufficient in form and substance; (2) the lack of proof of
MCLE compliance by the prosecutor who prepared and signed the Information should not prejudice the
interest of the State in filing charges against persons who have violated the law; and (3) and administrative
edict cannot prevail over substantive or procedural law, by imposing additional requirements for the
sufficiency of a criminal information.

The RTC dismissed the Information without prejudice. The prosecution’s motion for reconsideration was
also denied, hence the People of the Philippines filed a petition for certiorari and/or mandamus before the
Court of Appeals. The CA, however, dismissed the petition. It held that the prosecution was not without
any recourse other than a petition for certiorari/mandamus as it may simply re-file the Information as the
dismissal thereof was without prejudice. Thus, the People of the Philippines represented by the Office of
the City Prosecutor of Roxas City filed the instant petition for review on certiorari to assail the CA decision.

Issue: Whether or not the Motion to Dismiss the Information was proper for failure of the Investigating
Prosecutor to vindicate her MCLE Certificate of Compliance as required under Bar Matter No. 1922.

Ruling:

The petition lacks merit.

Pertinent portions of B.M. No. 1922, provide as follows:

The Court further Resolved, upon the recommendation of the Committee on Legal Education and Bar
Matters, to REQUIRE practicing members of the bar to INDICATE in all pleadings filed before the courts or
quasi-judicial bodies, the number and date of issue of their MCLE Certificate of Compliance or Certificate
of Exemption, as may be applicable, for the immediately preceding compliance period. Failure to disclose
the required information would cause the dismissal of the case and the expunction of the pleadings from
the records.

xxxx

Under Section 4, Rule 110 of the same Rules, an information is defined as an accusation in writing charging
a person with an offense, subscribed by the prosecutor and filed with the court. In accordance with the
above definitions, it is clear that an information is a pleading since the allegations therein, which charge a
person with an offense, is basically the same as a complaint in a civil action which alleges a plaintiffs cause
or cause of action

As to petitioner’s contention that the failure of the investigating prosecutor to indicate in the subject
Information the number and date of issue of her MCLE Certificate of Compliance is a mere formal defect
and is not a valid ground to dismiss such Information, suffice it to state that B.M. No. 1922 categorically
provides that “[f]ailure to disclose the required information would cause the dismissal of the case and the
expunction of the pleadings from the records.”

The Court agrees with the CA that the dismissal of the Information, without prejudice, did not leave the
prosecution without any other plain, speedy and adequate remedy. To avoid undue delay in the disposition
of the subject criminal case and to uphold the parties’ respective rights to a speedy disposition of their
case, the prosecution, mindful of its duty not only to prosecute offenders but more importantly to do
justice, could have simply re-filed the Information containing the required number and date of issue of the
investigating prosecutor’s MCLE Certificate of Compliance, instead of resorting to the filing of various
petitions in court to stubbornly insist on its position and question the trial court’s dismissal of the subject
Information, thereby wasting its time and effort and the State’s resources.

Even when the motion for reconsideration of the RTC Order dismissing the subject Information was filed,
the required number and date of issue of the investigating prosecutor’s MCLE Certificate of Compliance
was still not included nor indicated. Thus, in the instant case, absent valid and compelling reasons, the
requested leniency and liberality in the observance of procedural rules appear to be an afterthought,
hence, cannot be granted.

In any event, to avoid inordinate delays in the disposition of cases brought about by a counsel’s failure to
indicate in his or her pleadings the number and date of issue of his or her MCLE Certificate of Compliance,
this Court issued an En Bane Resolution, dated January 14, 2014 which amended B.M. No. 1922 by
repealing the phrase “Failure to disclose the required information would cause the dismissal of the case
and the expunction of the pleadings from the records” and replacing it with “Failure to disclose the required
information would subject the counsel to appropriate penalty and disciplinary action.” Thus, under the
amendatory Resolution, the failure of a lawyer to indicate in his or her pleadings the number and date of
issue of his or her MCLE Certificate of Compliance will no longer result in the dismissal of the case and
expunction of the pleadings from the records. Nonetheless, such failure will subject the lawyer to the
prescribed fine and/or disciplinary action.

In light of the above amendment, while the same was not yet in effect at the time that the subject
Information was filed, the more prudent and practical thing that the trial court should have done in the
first place, so as to avoid delay in the disposition of the case, was not to dismiss the Information but to
simply require the investigating prosecutor to indicate therein the number and date of issue of her MCLE
Certificate of Compliance.

---0---

Tickler: This case talks about how criminal cases should be consolidated so as not to defeat the purpose of
promoting a more expeditious and less expensive resolution of the controversy of cases involving the same
business transaction.

Doctrine: Sec. 22, Rule 119 of the Rules of Court stating: Sec. 22.Consolidation of trials of related offenses.
– Charges for offenses founded on the same facts or forming part of a series of offenses of similar character
may be tried jointly at the discretion of the court.

Case Title:
ROMULO L. NERI v. SANDIGANBAYAN +
GR No. 202243, Aug 07, 2013
VELASCO JR., J.

Facts:

Petitioner Romulo L. Neri (Neri) served as Director General of the National Economic and Development
Authority (NEDA) during the administration of former President Gloria Macapagal-Arroyo. In connection
with the botched Philippine-ZTE National Broadband Network (NBN) Project, the Ombudsman filed two
criminal information, the first against Abalos, and the second against Neri. The Office of the Special
Prosecutor then moved for the two cases’ consolidation, to promote a more expeditious and less expensive
resolution of the controversy of cases involving the same business transaction.

Issue: WON Consolidation of the two cases is proper.

Ruling:

NO. Consolidation is a procedural device granted to the court as an aid in deciding how cases in its docket
are to be tried so that the business of the court may be dispatched expeditiously while providing justice to
the parties. Toward this end, consolidation and a single trial of several cases in the court's docket or
consolidation of issues within those cases are permitted by the rules. The term "consolidation" is used in
three (3) different senses or concepts, thus: a (1)Where all except one of several actions are stayed until
one is tried, in which case the judgment [in one] trial is conclusive as to the others. This is not actually
consolidation but is referred to as such. (quasi consolidation) (2)Where several actions are combined into
one, lose their separate identity, and become a single action in which a single judgment is rendered. This is
illustrated by a situation where several actions are pending between the same parties stating claims which
might have been set out originally in one complaint. (actual consolidation) (3)Where several actions are
ordered to be tried together but each retains its separate character and requires the entry of a separate
judgment. This type of consolidation does not merge the suits into a single action, or cause the parties to
one action to be parties to the other. (consolidation for trial).

To be sure, consolidation, as taken in the above senses, is allowed, as Rule 31 of the Rules of Court is
entitled "Consolidation or Severance." And Sec. 1 of Rule 31 provides: Section 1.Consolidation. – When
actions involving a common question of law or fact are pending before the court, it may order a joint
hearing or trial of any or all the matters in issue in the actions; it may order all actions consolidated; and it
may make such orders concerning proceedings therein as may tend to avoid unnecessary costs or delay.

The counterpart, but narrowed, rule for criminal cases is found in Sec. 22, Rule 119 of the Rules of Court
stating: Sec. 22.Consolidation of trials of related offenses. – Charges for offenses founded on the same facts
or forming part of a series of offenses of similar character may be tried jointly at the discretion of the court.
As complemented by Rule XII, Sec. 2 of the Sandiganbayan Revised Internal Rules which states: Section
2.Consolidation of Cases. – Cases arising from the same incident or series of incidents, or involving common
questions of fact and law, may be consolidated in the Division to which the case bearing the lowest docket
number is raffled. The prosecution anchored its motion for consolidation partly on the aforequoted Sec. 22
of Rule 119 which indubitably speaks of a joint trial.||| Joint trial is permissible "where the [actions] arise
from the same act, event or transaction, involve the same or like issues, and depend largely or substantially
on the same evidence, provided that the court has jurisdiction over the cases to be consolidated and that
a joint trial will not give one party an undue advantage or prejudice the substantial rights of any of the
parties."

More elaborately, joint trial is proper where the offenses charged are similar, related, or connected, or are
of the same or similar character or class, or involve or arose out of the same or related or connected acts,
occurrences, transactions, series of events, or chain of circumstances, or are based on acts or transactions
constituting parts of a common scheme or plan, or are of the same pattern and committed in the same
manner, or where there is a common element of substantial importance in their commission, or where the
same, or much the same, evidence will be competent and admissible or required in their prosecution, and
if not joined for trial the repetition or reproduction of substantially the same testimony will be required on
each trial.

Criminal prosecutions primarily revolve around proving beyond reasonable doubt the existence of the
elements of the crime charged. As such, they mainly involve questions of fact. There is a question of fact
when the doubt or difference arises from the truth or the falsity of the allegations of facts. Put a bit
differently, it exists when the doubt or difference arises as to the truth or falsehood of facts or when the
inquiry invites calibration of the whole gamut of evidence considering mainly the credibility of the
witnesses, the existence and relevancy of specific surrounding circumstances as well as their relation to
each other and to the whole, and the probability of the situation.

A consolidation of the Neri case to that of Abalos would expose petitioner Neri to testimonies which have
no relation whatsoever in the case against him and the lengthening of the legal dispute thereby delaying
the resolution of his case. Consolidation here would force petitioner to await the conclusion of testimonies
against Abalos, however irrelevant or immaterial as to him (Neri) before the case against the latter may be
resolved – a needless, hence, oppressive delay in the resolution of the criminal case against him.

---0---

Tickler: This case discusses that an amendment or change of the time of the commission of the crime, when
the disparity is not so great, is only a formal amendment in the information. A formal amendment does not
require a subsequent arraignment as the purpose of which is to INFORM THE NATURE AND CAUSE OF THE
ACCUSATION.

Doctrine: Sec. 14, Rule 110 of the Revised Rules on Criminal Procedure provides that, “[a] complaint or an
Information may be amended, in form or in substance, without leave of court, at any time before the accused
enters his plea. After the plea and during trial, a formal amendment may only be done with leave of court
and when it can be done without causing prejudice to the rights of the accused.”

Case Title:
LETICIA I. KUMMER v. PEOPLE +
GR No. 174461, Sep 11, 2013
BRION, J.

Facts:

On one fateful night, the evidence of the prosecution reveals, Johan Kummer, a minor, the son of Leticia
Kummer, shot a certain Jesus Mallo, Jr. According to the eyewitness, Amiel Malana, he and Jesus Mallo
went to the house of Kummer's. Jesus knocked on the door of the Kummer’s house, declaring that he is
“Boy Mallo”. Then, according to the testimonies of Malana, Johan shot Mallo dead with a shotgun. Being a
minor, Johan was released at the cognizance of his father. Then he left the country without notifying the
court. In defense, Leticia Kummer produced another version of the story which shows that they were
sleeping innocently in their house on that fateful night, when there was a commotion outside their house,
admitting however that, when they were practically disturbed by the said commotion, Johan got a shotgun
and fired outside their house, without intention to kill or injure anybody, especially Jesus. An Information
was filed with the Court on January 12, 1989, which was later on modified. This modification was about the
date of the commission of the crime. The modification, however, happened after she was arraigned. The
RTC convicted her and Johan, who was out of the Philippine Legal System’s reach. She appealed the case
to the CA, which was denied and affirmed the RTC's decision, arguing, among others, that by virtue of the
amendment of the Information, she should have been arraigned again; and, since she was not, there was
a blatant violation of her right to be informed of the nature of her case, since an amended Information is a
new Information. Hence, all proceedings which the case had undergone were void

Issue: Does she have to be arraigned again?

Ruling:

No. She does not have to be arraigned again. Note that only the date was amended. Sec. 14, Rule 110 of
the Revised Rules on Criminal Procedure provides that, “[a] complaint or an Information may be amended,
in form or in substance, without leave of court, at any time before the accused enters his plea. After the
plea and during trial, a formal amendment may only be done with leave of court and when it can be done
without causing prejudice to the rights of the accused.” Accordingly, a change in time in the commission of
the crime, when the disparity is not so great, is only a formal amendment. In view of the foregoing, the
amendment was from “July” to “June” can only be regarded as formal amendment. Moreover, it does not
and could not prejudice the rights of the accused, because (1) it does not change the nature of the crime,
and (2) it does not render the defenses prepared for the former Information as it stood invalid. Having said
all these, a formal amendment does not require a subsequent arraignment as the purpose of which is to
INFORM THE NATURE AND CAUSE OF THE ACCUSATION. Since the nature and cause of the accusation are
not changed by a formal amendment, a re-arraignment is not necessary, as she was already informed of
these things. Hence, there has been no violation of her rights as accused.

Hence, she does not have to be arraigned again.

---0---

Tickler: This case talks about how criminal actions are enjoined subject to certain exceptions as provided by
the Rules of Court.

Doctrine: Criminal prosecutions may not be restrained, either through a preliminary or final injunction or a
writ of prohibition, except in the following instances: (1) To afford adequate protection to the constitutional
rights of the accused; (2) When necessary for the orderly administration of justice or to avoid oppression or
multiplicity of actions; (3) When there is a prejudicial question which is sub-judice; (4) When the acts of the
officer are without or in excess of authority; (5) Where the prosecution is under an invalid law, ordinance or
regulation; (6) When double jeopardy is clearly apparent; (7) Where the Court has no jurisdiction over the
offense; (8) Where it is a case of persecution rather than prosecution; (9) Where the charges are manifestly
false and motivated by lust for vengeance; (10) When there is clearly no prima facie case against the accused
and a motion to quash on that ground has been denied; (11) Preliminary injunction has been issued by the
Supreme Court to prevent the threatened unlawful arrest of petitioners.”

Case Title:
DIRECTOR GUILLERMO T. DOMONDON, petitioner, vs. THE HONORABLE SANDIGANBAYAN

G.R. No. 129904. March 16, 2000

BUENA, J.

Facts:
On February and May 1994, four separate information were filed at the Sandiganbayan against certain
officials of the Philippine National Police due to the discovery of a chain of irregularities within the PNP
Commands. The petitioner was included as an accused on account of his approval of the Advice Allotment
in the amount of P5M and P15M respectively which amounts to a violation of the AntiGraft Law under Sec
3 of RA 3019.

On May 17, 1994, the Sandiganbayan issued 2 orders, the first was ordering the prosecution to
demonstrate probable complicity in the transaction described in the information and the second order was
deferring action on the motion for consolidation considering the uncertainty of the Court in proceeding the
case at this time and considering that only one of the 15 accused filed a motion for consolidation. A Motion
to Admit Amended Information was filed with the Sandiganbayan on August 26, 1997 and included
petitioner as they were recommended for further prosecution by the Ombudsman. Petitioner alleges that
respondents Desierto, Villa and Tamayo acted with grave abuse of discretion in denying his motion for
consolidation, claiming that since all of the pertinent cases have been remanded by the Sandiganbayan to
the Office of the Special Prosecutor under the Office of the Ombudsman for reinvestigation, "jurisdiction
has reverted" in the latter and "…it is grave abuse of discretion to refuse to perform the duty of
consolidating these cases.

Issue: Whether or not Sandiganbayan should be enjoined from proceeding with the hearing and other
incidents of Criminal Case No. 20574 against the petitioner during the pendency of the petition.

Ruling:

No. The Supreme Court held that the contentions of the petitioner are untenable. The Court explained :
“Well settled is the rule that criminal prosecutions may not be restrained, either through a preliminary or
final injunction or a writ of prohibition, except in the following instances: (1) To afford adequate protection
to the constitutional rights of the accused; (2) When necessary for the orderly administration of justice or
to avoid oppression or multiplicity of actions; (3) When there is a prejudicial question which is sub-judice;
(4) When the acts of the officer are without or in excess of authority; (5) Where the prosecution is under
an invalid law, ordinance or regulation; (6) When double jeopardy is clearly apparent; (7) Where the Court
has no jurisdiction over the offense; (8) Where it is a case of persecution rather than prosecution; (9) Where
the charges are manifestly false and motivated by lust for vengeance; (10) When there is clearly no prima
facie case against the accused and a motion to quash on that ground has been denied; ella (11) Preliminary
injunction has been issued by the Supreme Court to prevent the threatened unlawful arrest of petitioners.”

Corollary to the rule, the courts cannot interfere with the discretion of the fiscal or Ombudsman to
determine the specificity and adequacy of the averments of the offense charged. He may dismiss the
complaint forthwith if he finds it to be insufficient in form or substance or if he otherwise finds no ground
to continue with the inquiry; or he may proceed with the investigation if the complaint is, in his view, in
due and proper form.

However, while the Ombudsman has the full discretion to determine whether or not a criminal case should
be filed, this Court is not precluded from reviewing the Ombudsman’s action when there is an abuse of
discretion, by way of Rule 65 of the Rules of Court. Thus, we proceed to determine whether the
respondents Ombudsman Desierto and Overall Deputy Ombudsman Villa acted with grave abuse of
discretion. Grave abuse of discretion implies such capricious and whimsical exercise of judgment as is
equivalent to lack of jurisdiction. Such arbitrariness or despotism does not obtain here. With regard to
respondents’ denial of petitioner’s motion for consolidation of Crim. Case No. 20574 with Crim. Case Nos.
20185, 20191, 20192, 20576 and 22098, we find the same to be well-founded. While the Ombudsman has
full discretion to determine whether or not a criminal case should be filed in the Sandiganbayan, once the
case has been filed with said court, it is the Sandiganbayan, and no longer the Ombudsman, which has full
control of the case so much so that the information may not be dismissed, or in the instant case, may not
be consolidated with other pending cases, without the approval of the said court. Thus, the Court dismissed
the petition for prohibition and prayer for issuance of preliminary injunction to nullify the order of the
Ombudsman.

---0---

Tickler: This case clearly explains that Jurisdiction over the subject matter in a criminal case cannot be
conferred upon the court by the accused, by express waiver or otherwise. That jurisdiction is conferred by
the sovereign authority that organized the court and is given only by law in the manner and form prescribed
by law.

Doctrine: In criminal cases, venue is jurisdictional. A court cannot exercise jurisdiction over a person charged
with an offense committed outside its limited territory.

In a criminal case, the prosecution must not only prove that the offense was committed, it must also prove
the identity of the accused and the fact that the offense was committed within the jurisdiction of the court.

Case Title:
HECTOR TREAS, Petitioner, versus PEOPLE OF THE PHILIPPINES, Respondent.

G. R. No. 195002

SERENO, J.

Facts:

A house-and-lot in Iloilo City covered by TCT No. 109266 and availed the services of herein petitioner, Atty.
Hector Treas (Hector) regarding the transfer of the title in the Former’s name. Hector informed Elizabeth
that for the titling of the property in the name of her aunt Margarita, the following expenses would be
incurred: 1)P20,000.00- Attorneys fees; 2) P90,000.00-Capital Gains Tax; 3) P24,000.00- Documentary
Stamp, and 4) P10,000.00- Miscellaneous Expenses. Thereafter, Elizabeth gave P150,000.00 to Hector who
issued a corresponding receipt dated December 22, 1999 and prepared [a] Deed of Sale with Assumption
of Mortgage. Subsequently, Hector gave Elizabeth Revenue Official Receipts with official receipt nos.
covering P96,000.00 and P24,000.00. However, she was informed by the BIR that the receipts were fake.

Hector admitted to her that the receipts were fake and that he used the P120,000.00 for his other
transactions. To settle his accounts, Hector issued in favor of Elizabeth a Bank of Commerce check dated
November 10, 2000 in the amount of P120,000.00, deducting from P150,000.00 the P30,000.00 as
attorneys fees. When the check was deposited with the PCIBank, Makati Branch, the same was dishonored
for the reason that the account was closed. Notwithstanding, repeated formal and verbal demands,
appellant failed to pay. Thus, the instant case of Estafa was filed against him.

An information was filed by the Office of the City Prosecutor before the RTC, both of Makati which reads:
“That on or about the 23rd day of December, 1999, in the City of Makati, Metro Manila, Philippines and
within the jurisdiction of this Honorable Court, the above-named accused, received in trust from ELIZABETH
LUCIAJA the amount of P150,000.00” During arraignment, petitioner, entered a plea of Not Guilty. And due
to old age and poor health, and the fact that he lives in Iloilo City, petitioner was unable to attend the pre-
trial and trial of the case. On 8 January 2007, the RTC rendered a Decision finding petitioner guilty of the
crime of Estafa.

Hector appealed before the CA but the CA affirmed the RTC’s decision. Aggrieved, Hector appealed before
the Supreme Court and asserts that nowhere in the evidence presented by the prosecution does it show
that ₱150,000 was given to and received by petitioner in Makati City. Instead, the evidence shows that the
Receipt issued by petitioner for the money indicates only date, without any indication of the place where
it was issued. Petitioner claims that the only logical conclusion is that the money was actually delivered to
him in Iloilo City, especially since his residence and office were situated there as well. Thus, the trial court
failed to acquire jurisdiction over the case.

Issue: Can the Regional Trial Court of Makati acquire jurisdiction over the crime of estafa which the
prosecution failed to allege any of the acts material to such crime had occurred in Makati City?

Ruling:

No. The accused is correct in his argument that he is not required to present evidence to prove lack of
jurisdiction when such lack is already indicated in the prosecution evidence. As a settled principle in criminal
cases, venue is jurisdictional. A court cannot exercise jurisdiction over a person charged with an offense
committed outside its limited territory.

As explained in the case of Isip v. People, the place where the crime was committed determines not only
the venue of the action but is an essential element of jurisdiction. It is a fundamental rule that for
jurisdiction to be acquired by courts in criminal cases, the offense should have been committed or any one
of its essential ingredients should have taken place within the territorial jurisdiction of the court. Territorial
jurisdiction in criminal cases is the territory where the court has jurisdiction to take cognizance or to try the
offense allegedly committed therein by the accused. Thus, it cannot take jurisdiction over a person charged
with an offense allegedly committed outside of that limited territory.

Furthermore, the jurisdiction of a court over the criminal case is determined by the allegations in the
complaint or information. And once it is shown, the court may validly take cognizance of the case. However,
if the evidence adduced during the trial shows that the offense was committed somewhere else, the court
should dismiss the action for want of jurisdiction. Moreover, Section 15 (a) of Rule 110 of the Revised Rules
on Criminal Procedure of 2000 provides that subject to existing laws, the criminal action shall be instituted
and tried in the court of the municipality or territory where the offense was committed or where any of its
essential ingredients occurred. Hence, jurisdiction is conferred by the sovereign authority that organized
the court and is given only by law in the manner and form prescribed by law.

This Court consistently rules that it is unfair to require a defendant or accused to undergo the ordeal and
expense of a trial if the court has no jurisdiction over the subject matter or offense or it is not the court of
proper venue. In a criminal case, the prosecution must not only prove that the offense was committed, it
must also prove the identity of the accused and the fact that the offense was committed within the
jurisdiction of the court.

There is nothing in the documentary evidence offered by the prosecution that points to where the offense,
or any of its elements, was committed. A review of the testimony of Elizabeth also shows that there was
no mention of the place where the offense was allegedly committed. Although the prosecution alleged that
the check issued by petitioner was dishonored in a bank in Makati, such dishonor is not an element of the
offense of estafa under Article 315, par. 1 (b) of the RPC. There being no showing that the offense was
committed within Makati, the RTC of that city has no jurisdiction over the case.

---0---

Tickler: The case discusses how jurisdiction of the court is acquired over criminal cases involving continuing
or transitory crimes, particularly B.P. 22 cases.

Doctrine: A person charged with a continuing or transitory crime may be validly tried in any municipality or
territory where the offense was in part committed. Applying these principles, a criminal case for violation of
BP 22 may be filed in any of the places where any of its elements occurred – in particular, the place where
the check is drawn, issued, delivered, or dishonored.

Case Title:
ARMILYN MORILLO v. PEOPLE +
GR No. 198270, Dec 09, 2015
PERALTA, J.

Facts:

Sometime in July 2003, respondent Richard Natividad, Milo Malong and Bing Nanquil, introducing
themselves as contractors doing business in Pampanga City under the name and style of RB Custodio
Construction, purchased construction materials for their project inside the Subic Freeport Zone from
petitioner Armilyn Morillo, owner of Amasea General Merchandize and Construction Supplies. The parties
agreed that twenty percent (20%) of the purchases shall be paid within seven (7) days after the first delivery
and the remaining eighty percent (80%) to be paid within thirty-five (35) days after the last delivery, all of
which shall be via postdated checks.

Pursuant to the agreement, petitioner delivered construction materials amounting to a total of

P500,054.00 at the construction site where respondent and his partners were undertaking their project.
After the last delivery, respondent paid P20,000.00 in cash and issued two (2) post-dated checks, drawn
from Metrobank, Pampanga branch, in the amounts of P393,000.00 and P87,054.00. Upon maturity,
petitioner attempted to deposit the checks in her savings account at Equitable PCI Bank, San Lorenzo,
Makati City. They were, however, dishonored by the drawee bank.

Immediately thereafter, petitioner communicated the dishonor to respondent and his partners and
demanded for payment. Again, respondent issued two (2) post-dated Metrobank checks and assured
petitioner that they will be honored upon maturity. Upon deposit in her savings account at Equitable PCI
Bank, Makati Branch, the checks were once again dishonored for the reason that the account from which
they were drawn was already a closed account. Consequently, petitioner made several demands from
respondent and his partners, but to no avail, prompting her to file a complaint with the City Prosecution
Office, Makati City. Thus, on August 12, 2004, two (2) Informations were filed against respondent and Milo
Malong.

Issue: Whether or not MeTC of Makati City has jurisdiction over the case.

Ruling:

Yes. It is well settled that violation of BP 22 cases is categorized as transitory or continuing crimes, which
means that the acts material and essential thereto occur in one municipality or territory, while some occur
in another. Accordingly, the court wherein any of the crime’s essential and material acts have been
committed maintains jurisdiction to try the case; it being understood that the first court taking cognizance
of the same excludes the other. Stated differently, a person charged with a continuing or transitory crime
may be validly tried in any municipality or territory where the offense was in part committed. Applying
these principles, a criminal case for violation of BP 22 may be filed in any of the places where any of its
elements occurred – in particular, the place where the check is drawn, issued, delivered, or dishonored.

Guided by the foregoing pronouncements, there is no denying, therefore, that the court of the place where
the check was deposited or presented for encashment; can be vested with jurisdiction to try cases involving
violations of BP 22. Thus, the fact that the check subject of the instant case was drawn, issued, and delivered
in Pampanga does not strip off the Makati MeTC of its jurisdiction over the instant case for it is undisputed
that the subject check was deposited and presented for encashment at the Makati Branch of Equitable PC
IBank. The MeTC of Makati, therefore, correctly took cognizance of the instant case and rendered its
decision in the proper exercise of its jurisdiction.

First of all, the Court stresses that the appellate court’s dismissal of the case is not an acquittal of
respondent. Basic is the rule that a dismissal of a case is different from an acquittal of the accused therein.
Except in a dismissal based on a Demurrer to Evidence filed by the accused, or for violation of the right of
the accused to a speedy trial, the dismissal of a criminal case against the accused will not result in his
acquittal. In the oft-cited People v. Salico, the Court explained: This argument or reasoning is predicated
on a confusion of the legal concepts of dismissal and acquittal. Acquittal is always based on the merits, that
is, the defendant is acquitted because the evidence does not show that defendant’s guilt is beyond a
reasonable doubt; but dismissal does not decide the case on the merits or that the defendant is not guilty.
Dismissal terminates the proceeding, either because the court is not a court of competent jurisdiction, or
the evidence does not show that the offense was committed within the territorial jurisdiction of the court,
or the complaint or information is not valid or sufficient in form and substance, etc.
The only case in which the word dismissal is commonly but not correctly used, instead of the proper term
acquittal, is when, after the prosecution has presented all its: evidence, the defendant moves for the
dismissal and the court dismisses the ease on the ground that the evidence fails to show beyond a
reasonable doubt that the defendant is guilty; for in such case the dismissal is in reality an acquittal because
the case is decided on the merits. If the prosecution fails to prove that the offense was committed within
the territorial jurisdiction of the court and the case is dismissed, the dismissal is not an acquittal, inasmuch
as if it were so the defendant could not be again prosecuted before the court of competent jurisdiction;
and it is elemental that in such case, the defendant may again be prosecuted for the same offense before
a court of competent jurisdiction.

Thus, when the appellate court herein dismissed the instant case on the ground that the MeTC lacked
jurisdiction over the offense charged, it did not decide the same on the merits, let alone resolve the issue
of respondent’s guilt or innocence based on the evidence proffered by the prosecution. The appellate court
merely dismissed the case on the erroneous reasoning that none of the elements of BP 22 was committed
within the lower court’s jurisdiction, and not because of any finding that the evidence failed to show
respondent’s guilt beyond reasonable doubt. Clearly, therefore, such dismissal did not operate as an
acquittal, which, as previously discussed, may be repudiated only by a petition for certiorari under Rule 65
of the Rules of Court, showing a grave abuse of discretion. Thus, petitioner’s resort to Rule 45 of the Rules
of Court cannot be struck down as improper. In a petition for review on certiorari under Rule 45, the parties
raise only questions of law because the Court, in its exercise of its power of review, is not a trier of facts.
There is a question of law when the doubt or difference arises as to what the law is on certain state of facts
and which does not call for an existence of the probative value of the evidence presented by the parties-
litigants.

In the instant case; the lone issue invoked by petitioner is precisely “whether the Court of Appeals erred
when it ruled that the Metropolitan Trial Court of Makati City did not have jurisdiction over the case despite
clear showing that the offense was committed within the jurisdiction of said court.” Evidently, therefore,
the instant petition was filed within the bounds of our procedural rules for the issue herein rests solely on
what the law provides on the given set of circumstances insofar as the commission of the crime of BP 22 is
concerned. In criminal cases, the jurisdiction of the court is determined by the averments of the complaint
or Information, in relation to the law prevailing at the time of the filing of the complaint or Information,
and the penalty provided by law for the crime charged at the time of its commission. Thus, when a case
involves a proper interpretation of the rules and jurisprudence with respect to the jurisdiction of courts to
entertain complaints filed therewith, it deals with a question of law that can be properly brought to this
Court under Rule 45.

---0---

Tickler: Though as a general rule, rules of procedures are liberally construed, the provisions with respect to
the rules on the manner and periods for perfecting appeals are strictly applied and are only relaxed in very
exceptional circumstances on equitable considerations, which are not present in the instant case.

Doctrine: The perfection of an appeal within the period and in the manner prescribed by law is jurisdictional
and noncompliance with such requirements is considered fatal and has the effect of rendering the judgment
final and executory.
Case Title:
FELY Y. YALONG, Petitioner, v. PEOPLE OF THE PHILIPPINES AND LUCILA C. YLAGAN,Respondents.

G.R. No. 187174, August 28, 2013

PERLAS-BERNABE, J.

Facts:

Respondent Ylagan filed a criminal complaint against Petitioner Yalong for the crime of violation of BP 22.
Upon arraignment, Yalong pleaded not guilty to the said charge. The case was then set for pre-trial and
therafter, trial ensued. During the trial, Ylagan testifies that Yalong borrowed from her 450,000 with a
verbal agreement that the same would be paid back to her in cash, and as payment therof, issued to her a
postdated check in the similar amount. However, when Ylagan presented the subject check for payment, it
was dishonored and returned to her for the reason of “Account Closed”. After several demands from
Yalong, Ylagan filed the instant case.

Yalong averred that she already paid the said loan but did not require Ylagan to issue a receipt or
acknowledge the same. She also claimed that the subject check belonged to her husband and that while
she knew that the said check did not cover sufficient funds, it was already signed by her husband when she
handed it to Ylagan. The MTCC found Yalong guilty. A motion for reconsideration was denied. She then filed
a notice of appeal which was also denied on the ground that Yalong had lost the remedies available to her
under the law when she failed to appear without justifiable reason at the scheduled promulgation of the
MTCC Decision, she did not surrender within 15 days from the date of such promulgation, she did not file
a motion for leave of court to avail of the remedies under the law, and she remained at large.

She filed a motion for reconsideration which was, however, denied. Aggrieved, Yalong filed a Petition for
Certiorari with Petition for Bail (certiorari petition) before the RTC which denied the petition. The CA
dismissed the subject petition for review on the ground that the order of the RTC was issued in the exercise
of its original jurisdiction – where appeal [by filing a notice of appeal with the RTC] – and not a petition for
review is the proper remedy. Yalong filed a motion for reconsideration which was, however, denied. Hence,
this petition.

Issue: Whether or not the CA properly dismissed the subject petition for review on the ground of
improper appeal.

Ruling:

No. While the Rules of Court do not specifically state that the inappropriate filing of a petition for review
instead of a required notice of appeal is dismissible, Section 2(a), Rule 41 of the Rules nonetheless provides
that appeals to the CA in cases decided by the RTC in the exercise of its original jurisdiction shall be taken
by filing a notice of appeal with the latter court. It is fundamental that a petition for certiorari is an original
action and, as such, it cannot be gainsaid that the RTC took cognizance of and resolved the aforesaid
petition in the exercise of its original jurisdiction. Hence, Yalong should have filed a notice of appeal with
the RTC instead of a petition for review with the CA.
As a consequence of Yalong’s failure to file a notice of appeal with the RTC within the proper reglementary
period, the RTC Decision had attained finality which thereby bars Yalong from further contesting the same.
Verily, jurisprudence dictates that the perfection of an appeal within the period and in the manner
prescribed by law is jurisdictional and noncompliance with such requirements is considered fatal and has
the effect of rendering the judgment final and executory. To be sure, the rules on appeal must be strictly
followed as they are considered indispensable to forestall or avoid unreasonable delays in the
administration of justice, to ensure an orderly discharge of judicial business, and to put an end to
controversies.

Though as a general rule, rules of procedures are liberally construed, the provisions with respect to the
rules on the manner and periods for perfecting appeals are strictly applied and are only relaxed in very
exceptional circumstances on equitable considerations, which are not present in the instant case. As it
stands, the subject petition for review was the wrong remedy and perforce was properly dismissed by the
CA.

---0---

Tickler: This case talks about the proper venue of criminal actions, particularly where the crime is perjury
and the false declarations in the Certificate against Forum Shopping were made before a notary public in
Makati City, despite knowledge that the material statements subscribed and sworn to were untrue.

Doctrine: Rule 110, Sec. 15 of the Rules of Court; Criminal action shall be instituted where the offense was
committed or where any of its essential elements occurred.

Case Title:
UNION BANK OF THE PHILIPPINES and DESI

TOMAS, versus PEOPLE OF THE PHILIPPINES

G.R. No. 192565, February 28, 2012

BRION, J.

Facts:

Desi Tomas was charged with perjury for making a false narration in a Certificate against Forum Shopping.
It was alleged that Tomas stated under oath that the Union Bank of the Philippines has not commenced
any other action or proceeding involving the same issues in another tribunal or agency aside from that
which is filed before the Regional Trial Court of Pasay City for the collection of sum of money with prayer
of writ of replevin filed against Eddie and Eliza Tamondong and a John Doe.

Tomas filed a motion to quash arguing that the Metropolitan Trial Court of Makati City does not have
jurisdiction over the case as, though it was notarized in Makati, the Certificate against Forum Shopping was
used or submitted before the Regional Trial Court of Pasay City.
Issue: Whether or not the Metropolitan Trial Court of Makati City has jurisdiction over the case at bar.

Ruling:

Tomas’ deliberate and intentional assertion of falsehood was allegedly shown when she made the false
declarations in the Certificate against Forum Shopping before a notary public in Makati City, despite her
knowledge that the material statements she subscribed and swore to were not true. Thus, Makati City is
the proper venue and MeTC-Makati City is the proper court to try the perjury case against Tomas, pursuant
to Section 15(a), Rule 110 of the 2000 Revised Rules of Criminal Procedure as all the essential elements
constituting the crime of perjury were committed within the territorial jurisdiction of Makati City, not Pasay
City.

---0---
Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:
Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:
Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:
Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:
 ---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:
Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:
Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:
Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:
 ---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:
Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---

Tickler:

Doctrine:

Case Title:
Facts:

Issue:

Ruling:

---0---