Isip v.

People of the Philippines

Facts:
Petitioner Manuel Isip was charged with Estafa beforethe RTC of Cavite City, after he
allegedly received fromcomplainant, Atty. Jose, a sevencarat diamond mens
ring valued at P200,000.00, for the purpose of selling thesame on commission basis
and to deliver the proceeds of the sale thereof or return the same if not
sold. Petitionerdenied receiving the jewelry and failed to return the ringor proceeds of
the sale even after repeated demand. On
the other hand, petitioners wife, Marietta Isip, was
indicted before the same court for 7 counts of Violationof BP 22 (Bouncing Checks Law)
after she issued checks inpayment for assorted pieces of jewelry she received fromAtty.
Jose which were subsequently dishonoured forinsufficiency of funds. The complainant
alleged that theforegoing transactions happened at his ancestral housein Cavite while
he was on leave of absence from theBureau of Customs. In defense, petitioner averred
thatthe RTC had no jurisdiction over the case because he andhis wife had transactions
with the complainant at the
latters residence located at Plaza Tower Condominium in
Manila as both of them were also Manila residents.Despite this, the trial court found
them guilty of the saidallegations. Upon appeal to the CA, Marietta Isip diedbefore any
decision could have been promulgatedthereby extinguishing her criminal and civil
liability.However, the CA still affirmed
Manuel Isips conviction
for estafa, hence this appeal.
Issue:
Whether the trial court had jurisdiction over the offenseimputed to petitioner and for
which he was convicted.
Held:
Yes. The complainant had sufficiently shown that thetransaction took place in his
home in Cavite. Since it hasbeen shown that venue was properly laid, it is now
petitioners task to prove otherwise. In the instant case,
petitioner failed to establish by sufficient and competentevidence that the transaction
happened in Manila due tothe following reasons:a.
Even if petitioner lives in Manila and the issuedchecks were drawn against banks in
Manila orMakati, it still does not prove that the transactionsdid not happen in Cavite.
Distance will not preventany person from going to a distant place where hecan procure
goods he can sell to earn a living.b.
It is settled that when the RTC s findings have been affirmed by the appellate court,
said findings aregenerally conclusive and binding upon this Court.

The concept of venue of actions in criminal cases, unlikein civil cases, is jurisdictional.
The place where the crimewas committed determines not only the venue of theaction
but is an essential element of jurisdiction. It is afundamental rule that for jurisdiction to
be acquired bycourts in criminal cases:a.
The offense should have been committed; orb.
Any one of its essential ingredients shouldve takenplace within the courts territorial
jurisdiction.Territorial jurisdiction in criminal cases is the territorywhere the court has
jurisdiction to take cognizance or totry the offense allegedly committed therein. Thus,
itcannot take jurisdiction over a person charged with anoffense committed outside that
territory. Furthermore,the jurisdiction of a court over the criminal case isdetermined by
the allegations in the complaint orinformation. Once it is so shown, the court may
validlytake cognizance of the case. However, if the evidenceadduced during the trial
shows that the offense wascommitted somewhere else, the court should dismissthe
action for want of jurisdiction.

Landbank of the Philippines v. Belista

Facts:
Spouses Ralla donated 8 parcels of lot located in Albay totheir daughter, Rene Ralla
Belista, herein privaterespondent. Consequently, the 8 parcels of lot wereplaced by
DAR under the coverage of the ComprehensiveAgrarian Reform Program. Belista then
claimed paymentof just compensation over said agricultural lands. DAR'sevaluation of
the
subject
farms
was
only
at
P227,582.58,while petitioner Land Bank assessed the same atP317,259.31. Believing
that her lots were grosslyunderestimated, Belista filed a Petition for Valuation
andPayment of Just Compensation against Landbank beforethe Regional Agrarian
Reform Adjudicator (RARAD). TheRARAD issued a Decision wherein the just
compensationfor the subject areas was fixed at P2,540,211.58.Aggrieved, petitioner
Landbank filed an original Petitionfor Determination of Just Compensation at the the
RTC.The RTC dismissed the case for failure to exhaustadministrative remedies and/or
comply with Sections 5,6, and 7, Rule XIX of the 2003 DARAB Rules of
Procedure.Landbank lodged a MFR arguing that the DARAB Rules of Procedure does
not apply to Special Agrarian Courts butthe court a quo still denied its MFR. Petitioner
Landbankelevated the case before the CA through a Petition forReview. The CA ruled
that under the 2003 DARAB Rulesof Procedure, an appeal from the adjudicator's
resolutionshould be filed before the Department of AgrarianReform Adjudication Board
(DARAB) and not before the RTC and that petitioner's filing of the case before the RTC
without first seeking the intervention of the DARAB isviolative of the doctrine of nonexhaustion of administrative remedies. Petitioner filed a MFR, but thesame was denied,
hence, this petition.

Issue:
Whether it is necessary that in cases involving claims for just compensation under RA
6657, the RARAD
s Decision
must first be appealed to DARAB before a party canresort to the RTC sitting as a
Special Agrarian Court.
Held:
No. Petitioner properly filed the petition before the RTCand, hence, the RTC erred in
dismissing the case.Section 56 of RA 6657 provides that DAR is vested withprimary
jurisdiction to determine and adjudicate agrarianreform matters and shall have exclusive
original jurisdiction over all matters involving the implementationof agrarian reform,
except those falling under theexclusive jurisdiction of the Department of Agricultureand
the Department of Environment and NaturalResources.
Section 57 of RA 6657 provides that theSpecial Agrarian Court shall have original and
exclusive jurisdiction over all petitions for:a)
Determination of just compensation to landowners;
b)
Prosecution of all criminal offenses under this Act.
Clearly, further exception to DAR's original andexclusive jurisdiction are all petitions for
determinationof just compensation to landowners and prosecution of all criminal
offenses under RA 6657, which are withinthe original and exclusive jurisdiction of the
RTC sittingas a Special Agrarian Court. Jurisdiction over the subjectmatter is conferred
by law. Only a statute can confer jurisdiction on courts and administrative agencies
whilerules of procedure cannot.