408 People V Ocaya

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REMEDIAL LAW REVIEW CASE DIGEST

TOPIC Jurisdiction determined by allegations in the Complaint or Information


CASE TITLE People v Judge Ocaya
GR NO. L-47448 DATE: May 17, 1978
DOCTRINE
It is elemental that the jurisdiction of a court in criminal cases is determined by the allegations of the
information or criminal complaint and not by the result of the evidence presented at the trial, 1 much less by
the trial judge’s personal appraisal of the affidavits and exhibits attached by the fiscal to the record of the
case without hearing the parties and their witnesses nor receiving their evidence at a proper trial.
FACTS
A charge of serious physical injuries was filed against private respondents but Judge Ocaya after scanning
the records and noting that the medical certificate stated that the injuries would require medical attention
from seven (7) to ten (10) days and therefore may either be slight or less serious physical injuries only and
without receiving the evidence or hearing the witnesses, precipitately dismissed the information for lack of
jurisdiction on the erroneous notion that in physical injury cases, the duration of the treatment of the injury
inflicted on the victim as indicated in the medical certificate determines the jurisdiction of the court.

The MR was denied; hence, the fiscal filed the petition for certiorari.
ISSUE
Whether or not the respondent judge committed grave abuse of discretion in dismissing the case?
HELD
YES. Respondent judge committed a grave abuse of discretion in precipitately dismissing the case for
alleged lack of jurisdiction on the mere basis of his totally wrong notion that what governs in the filing of a
physical injury case is the medical certificate regarding the duration of treatment and "not what the victim
declares because the same is self-serving."

It is elemental that the jurisdiction of a court in criminal cases is determined by the allegations of the
information or criminal complaint and not by the result of the evidence presented at the trial, much less by
the trial judge’s personal appraisal of the affidavits and exhibits attached by the fiscal to the record of the
case without hearing the parties and their witnesses nor receiving their evidence at a proper trial.

It is equally elementary that the mere fact that evidence presented at the trial would indicate that a lesser
offense outside the trial court’s jurisdiction was committed does not deprive the trial court of its jurisdiction
which had vested in it under the allegations of the information as filed since" (once) the jurisdiction attaches
to the person and subject matter of the litigation, the subsequent happening of events, although they are of
such a character as would have prevented jurisdiction from attaching in the first instance, will not operate to
oust jurisdiction already attached.
NOTES

4C (2020 – 2021)

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