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ANA LOU B. NAVAJA v. MANUEL A. DE CASTRO

1) Ana Lou Narvaja was charged with falsifying a receipt for meal expenses claimed for reimbursement from her employer DKT Philippines. 2) Narvaja filed a motion to quash the charges, arguing the court in Jagna, Bohol did not have jurisdiction since the falsification did not occur there. The motion was denied. 3) The Supreme Court ruled the MCTC of Jagna, Bohol did have jurisdiction, as the complaint alleged the falsification occurred in Jagna, making it the proper venue under the rules of criminal procedure.

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343 views1 page

ANA LOU B. NAVAJA v. MANUEL A. DE CASTRO

1) Ana Lou Narvaja was charged with falsifying a receipt for meal expenses claimed for reimbursement from her employer DKT Philippines. 2) Narvaja filed a motion to quash the charges, arguing the court in Jagna, Bohol did not have jurisdiction since the falsification did not occur there. The motion was denied. 3) The Supreme Court ruled the MCTC of Jagna, Bohol did have jurisdiction, as the complaint alleged the falsification occurred in Jagna, making it the proper venue under the rules of criminal procedure.

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Ken Tuazon
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We take content rights seriously. If you suspect this is your content, claim it here.
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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.

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