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    People Vs Atienza

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    Jerome Leaño
    The National Bureau of Investigation and Office of the Ombudsman filed a criminal complaint against Atienza, Castro, and Dario for falsification of public documents, violation of laws on graft and corruption, and violation of a code of conduct for public officials. After investigation, the charges involving violations of anti-graft laws were dismissed, but probable cause was found to charge them with robbery and falsification of public documents. The trial court found the defendants guilty on both charges, and the Court of Appeals affirmed the conviction. However, the Supreme Court held that the trial court did not have jurisdiction over the falsification charge since that offense fell under the exclusive jurisdiction of lower courts based on law.

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    People Vs Atienza

    Uploaded by

    Jerome Leaño
    166 views1 page
    The National Bureau of Investigation and Office of the Ombudsman filed a criminal complaint against Atienza, Castro, and Dario for falsification of public documents, violation of laws on graft and corruption, and violation of a code of conduct for public officials. After investigation, the charges involving violations of anti-graft laws were dismissed, but probable cause was found to charge them with robbery and falsification of public documents. The trial court found the defendants guilty on both charges, and the Court of Appeals affirmed the conviction. However, the Supreme Court held that the trial court did not have jurisdiction over the falsification charge since that offense fell under the exclusive jurisdiction of lower courts based on law.

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    People vs Atienza

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    The National Bureau of Investigation and Office of the Ombudsman filed a criminal complaint against Atienza, Castro, and Dario for falsification of public documents, violation of laws on graft and corruption, and violation of a code of conduct for public officials. After investigation, the charges involving violations of anti-graft laws were dismissed, but probable cause was found to charge them with robbery and falsification of public documents. The trial court found the defendants guilty on both charges, and the Court of Appeals affirmed the conviction. However, the Supreme Court held that the trial court did not have jurisdiction over the falsification charge since that offense fell under the exclusive jurisdiction of lower courts based on law.

    Copyright:

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

    People Vs Atienza

    Uploaded by

    Jerome Leaño
    The National Bureau of Investigation and Office of the Ombudsman filed a criminal complaint against Atienza, Castro, and Dario for falsification of public documents, violation of laws on graft and corruption, and violation of a code of conduct for public officials. After investigation, the charges involving violations of anti-graft laws were dismissed, but probable cause was found to charge them with robbery and falsification of public documents. The trial court found the defendants guilty on both charges, and the Court of Appeals affirmed the conviction. However, the Supreme Court held that the trial court did not have jurisdiction over the falsification charge since that offense fell under the exclusive jurisdiction of lower courts based on law.

    Copyright:

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

    People vs Atienza

    Facts:
    Consequently, a criminal complaint was filed by the NBI and the Fact–Finding and Intelligence
    Bureau of the Office of the Ombudsman against Atienza, Castro, and Dario before the
    Evaluation and Preliminary Investigation Bureau of the OMB, docketed as OMB–0–97–2054,
    charging them for the following crimes: (a) Falsification of Public Document; (b) violation of
    Section 3(a) of Republic Act No. (RA) 3019, as amended; and (c) violation of Section 8 of RA
    6713.

    After investigation, the charges involving the pertinent provisions of RAs 3019 and 6713 were
    dismissed for insufficiency of evidence, but it was contrarily determined that there existed
    probable cause to charge Atienza, Castro, and Dario for the crimes of Robbery under Article
    299(a)(1) of the Revised Penal Code (RPC), as amended, and of Falsification of Public
    Document under Article 172(1) in relation to Article 171(6) of the same code.

    After trial on the merits, the RTC rendered a Decision65 on June 8, 2006, finding petitioners
    guilty beyond reasonable doubt of the crimes of Robbery under Article 299(a)(1) of the RPC and
    Falsification of Public Document under Article 172(1) in relation to Article 171(6) of the RPC. In
    a Decision dated November 28, 2008, the CA affirmed the RTC’s judgment of conviction in toto.

    Issue:
    Whether or not the RTC did not have jurisdiction to take cognizance of Criminal Case No. 01–
    197426 (i.e., the falsification case) since Falsification of Public Document under Article 172(1) of
    the RPC, which is punishable by prision correccional in its medium and maximum periods (or
    imprisonment for 2 years, 4 months and 1 day to 6 years ) and a fine of not more than
    P5,000.00, falls within the exclusive jurisdiction of the Metropolitan Trial Courts, Municipal Trial
    Courts and Municipal Circuit Trial Courts pursuant to Section 32(2) of Batas Pambansa Bilang
    129.

    Held:
    Also, it bears mentioning that the RTC did not have jurisdiction to take cognizance of Criminal
    Case No. 01–197426 (i.e., the falsification case) since Falsification of Public Document under
    Article 172(1) of the RPC, which is punishable by prision correccional in its medium and
    maximum periods (or imprisonment for 2 years, 4 months and 1 day to 6 years ) and a fine of
    not more than P5,000.00, falls within the exclusive jurisdiction of the Metropolitan Trial Courts,
    Municipal Trial Courts and Municipal Circuit Trial Courts pursuant to Section 32(2) of Batas
    Pambansa Bilang 129, otherwise known as the “Judiciary Reorganization Act of 1980,” as
    amended by RA 7691. While petitioners raised this jurisdictional defect95 for the first time in the
    present petition, they are not precluded from questioning the same. Indeed, jurisdiction over the
    subject matter is conferred only by the Constitution or the law and cannot be acquired through a
    waiver or enlarged by the omission of the parties or conferred by the acquiescence of the court.
    The rule is well–settled that lack of jurisdiction over the subject matter may be raised at any
    stage of the proceedings. Hence, questions of jurisdiction may be cognizable even if raised for
    the first time on appeal.

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