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People of the Philippines v.

Taroy
G.R. No. 192466 September 7, 2011
THIRD DIVISION
FACTS:
Mila is Taroys wife. Mila has an eldest daughter from her first marriage named
Des. The couple lived with Milas children in Benguet at the boundary of
Baguio City.
According to Des, when she was still 10 years old, Taroy raped her when she
was alone cleaning their house. She was told not to tell anyone lest Mila and
her siblings would suffer harm. This incident was followed by another sexual
abuse on the next year. This time it occurred inside Des bedroom where
Taroy pointed a knife at her and ordered her to undress and submit to his
sexual desires.
Des only confided the story to her mother and aunt four years later. They
accompanied her to the NBI to complain. She also underwent medical
examination where it was revealed that there was indeed a history of
previous blunt force caused by an insertion of an erect penis. The public
prosecutor charged Taroy with two counts of before the RTC of La Trinidad,
Benguet. Correspondingly, the RTC convicted Taroy of the offense and
penalized him to suffer reclusion perpetua.
Taroy challenged the Benguet RTCs jurisdiction over the crimes charged
contending that their residence where the alleged offenses took place was at
the boundary of Baguio City.
The RTC held, however, that Taroys testimony that their
in Baguio City did not strip the court of its jurisdiction since
jurisdictional requirement. The Court of Appeals affirmed the
RTC. It held that the prosecution has sufficiently established
of the RTC.

residence was
he waived the
decision of the
the jurisdiction

Hence, this appeal.


ISSUE:
Whether or not the RTC of La Trinidad, Benguet has jurisdiction to hear the
rape cases against Taroy.
RULING:
Venue is jurisdictional in criminal cases. It can neither be waived nor
subjected to stipulation. The right venue must exist as a matter of law. Thus,

for territorial jurisdiction to attach, the criminal action must be instituted and
tried in the proper court of the municipality, city, or province where the
offense was committed or where any of its essential ingredients took place.
The information filed with the RTC of La Trinidad state that the crimes were
committed in the victim and the offenders house in City Limit, Tuding,
Municipality of Itogon, Province of Benguet. This allegation conferred
territorial jurisdiction over the subject offenses on the RTC of La Trinidad,
Benguet. The testimonies of Mila and Des as well as the affidavit of arrest
point to this fact. Clearly, Taroys uncorroborated assertion that the subject
offenses took place in Baguio City is not entitled to belief. Besides, he
admitted during the pre-trial in the case that it was the RTC of La Trinidad
that had jurisdiction to hear the case. Taken altogether, that RTCs
jurisdiction to hear the case is beyond dispute.