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    Fukuzume v. People

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    Reymart-Vin Maguliano
    The Supreme Court ruled that the Regional Trial Court of Makati did not have jurisdiction over the estafa case against Yusuke Fukuzume. The testimony established that all elements of the alleged crime, including the transaction between Fukuzume and the complainant, took place at Fukuzume's residence in Paranaque. For a court to have jurisdiction over a criminal case, the offense must have been committed or elements occurred within the court's territorial jurisdiction. As the prosecution failed to prove the crime was committed in Makati or that essential elements happened there, the Makati court did not have authority to convict Fukuzume. The conviction was set aside without prejudice for charges to be filed with the proper court.

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    Fukuzume v. People

    Uploaded by

    Reymart-Vin Maguliano
    725 views1 page
    The Supreme Court ruled that the Regional Trial Court of Makati did not have jurisdiction over the estafa case against Yusuke Fukuzume. The testimony established that all elements of the alleged crime, including the transaction between Fukuzume and the complainant, took place at Fukuzume's residence in Paranaque. For a court to have jurisdiction over a criminal case, the offense must have been committed or elements occurred within the court's territorial jurisdiction. As the prosecution failed to prove the crime was committed in Makati or that essential elements happened there, the Makati court did not have authority to convict Fukuzume. The conviction was set aside without prejudice for charges to be filed with the proper court.

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    Fukuzume v. People

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    The Supreme Court ruled that the Regional Trial Court of Makati did not have jurisdiction over the estafa case against Yusuke Fukuzume. The testimony established that all elements of the alleged crime, including the transaction between Fukuzume and the complainant, took place at Fukuzume's residence in Paranaque. For a court to have jurisdiction over a criminal case, the offense must have been committed or elements occurred within the court's territorial jurisdiction. As the prosecution failed to prove the crime was committed in Makati or that essential elements happened there, the Makati court did not have authority to convict Fukuzume. The conviction was set aside without prejudice for charges to be filed with the proper court.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    725 views1 page

    Fukuzume v. People

    Uploaded by

    Reymart-Vin Maguliano
    The Supreme Court ruled that the Regional Trial Court of Makati did not have jurisdiction over the estafa case against Yusuke Fukuzume. The testimony established that all elements of the alleged crime, including the transaction between Fukuzume and the complainant, took place at Fukuzume's residence in Paranaque. For a court to have jurisdiction over a criminal case, the offense must have been committed or elements occurred within the court's territorial jurisdiction. As the prosecution failed to prove the crime was committed in Makati or that essential elements happened there, the Makati court did not have authority to convict Fukuzume. The conviction was set aside without prejudice for charges to be filed with the proper court.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    G.R. No.

    143647 November 11, 2005

    YUSUKE FUKUZUME,* Petitioner,


    vs.
    PEOPLE OF THE PHILIPPINES,** Respondent.

    FACTS:

    In an Information filed with the RTC of Makati, Fukuzume was charged with estafa for making false representation and fraudulent
    manifestation that he is the duly authorized representative of Furukawa Electric Co. Ltd., in the Philippines.

    The trial court found Fukuzume guilty as charged and the same was affirmed by the CA on appeal.

    In his current petition, Fukuzume claims that RTC Makati has no jurisdiction over the case as the transaction between him and
    complainant Yu took place at his (Fukuzume) residence in Parañaque.

    ISSUE:

    Whether or not RTC of Makati has jurisdiction over the offense charged.

    HELD:

    No.

    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 took 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 so shown, the court may validly take cognizance of the case. However, if the evidence adduced
    during the trial show that the offense was committed somewhere else, the court should dismiss the action for want of
    jurisdiction.

    The testimony of Yu established that all the elements of the offense charged had been committed in Parañaque, to wit: that on July
    12, 1991, Yu went to the house of Fukuzume in Parañaque; that with the intention of selling the subject aluminum scrap wires, the
    latter pretended that he is a representative of Furukawa who is authorized to sell the said scrap wires; that based on the false
    pretense of Fukuzume, Yu agreed to buy the subject aluminum scrap wires; that Yu paid Fukuzume the initial amount of
    ₱50,000.00; that as a result, Yu suffered damage. Stated differently, the crime of estafa, as defined and penalized under Article
    315, paragraph 2(a) of the Revised Penal Code, was consummated when Yu and Fukuzume met at the latter’s house in Parañaque
    and, by falsely pretending to sell aluminum scrap wires, Fukuzume was able to induce Yu to part with his money.

    From the foregoing, it is evident that the prosecution failed to prove that Fukuzume committed the crime of estafa in Makati or
    that any of the essential ingredients of the offense took place in the said city. Hence, the judgment of the trial court convicting
    Fukuzume of the crime of estafa should be set aside for want of jurisdiction, without prejudice, however, to the filing of
    appropriate charges with the court of competent jurisdiction.

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