University of the Philippines College of Law

JEBJ, 1-D

Topic Venue
Case No. G.R. No. L-25795/ October 29, 1966
Case Name Lopez v. City
Ponente Justice Dizon

RELEVANT FACTS
 On Februrary 1964, Roy P. Villasor who was administrator of the estates of the Spouses Mejia along
with Angelina Lopez, Aurora Villasor and other heirs entered into a contract with Trinidad Lazatin for the
development and subdivision of three parcels of land belonging to the intestate estate who then
transferred his rights to the Terra Development Corporation. A few months later they filed for the
recission of said contract for alleged gross and willful violations of its terms.

 Lazatin et. al. then filed a complaint with the City Fiscal of Angeles a complaint for the falsification of a
private documents. Following a preliminary investigation, the Fiscal then filed an information against the
Villasors for having pretended in the contract that Aurora Villasor was the guardian of the minors
George Mejia and Angelina Lopez when she wasn’t.

 The Villasors filed a petition that caused a reinvestigation by the Fiscal to give them an opportunity to
present exculpatory evidence and after reinvestigation moved for a dismissal of the case claiming the
fiscal had not authority citing that the document was signed outside Angeles’ territorial limits. The
resolution of the motion to dismiss was delayed and in the meantime the Court set the criminal case for
arraignment but this was postponed several times by the defendants.

 On November 26, 1965 the Villasors filed a motion to dismiss citing that the City Fiscal had no
jurisdiction. The Fiscal filed an opposition thereto and on February 3, 1966 the respondent Judge denied
the motion to dismiss and reset the arraignment for March 5, 1966.

 Petitioners then filed a Petition for Certiorari and Prohibition to elevate the case before the Supreme
Court.

ISSUE
W/N The Fiscal has the Jurisdiction to hear and try the case?

RATIO DECIDENDI

Issue Ratio
W/N The Fiscal has the YES
Jurisdiction to hear and try
the case? 1. The Supreme Court held that the crime of falsification of private
documents is consummated when the document is actually falsified with the
intent of a third person. The Court noted that the part of the record
containing details of the reinvestigation in connection with the Motion to
 University of the Philippines College of Law
JEBJ, 1-D

Quash showed that offense was committed beyond the jurisdiction of

Angeles City.

2. The Court also held that as a general rule, a court of equity will not issue a
writ of certiorari to annul an order of a lower court denying a motion to
quash or a writ of prohibition to prevent said court from proceeding with a
case after such denial, due to the rule that the defendant should plead not
guilty and then go to trial.

RULING

WHEREFORE, … judgment is hereby rendered declaring that the offense charged in the information filed in
Criminal Case No. C-2268 of the City Court of Angeles City is not within the jurisdiction of said court and that,
therefore, said court is hereby restrained and prohibited from further proceedings therein. Costs against the private
respondents.

SEPARATE OPINIONS

NOTES