This case discusses a land dispute between David and Agbay over 600 square meters of land in Oriental Mindoro that David bought in 2000 and later found out was public land. In 2011, David filed a motion for re-determination of probable cause with the MTC regarding a criminal complaint for falsifying documents that Agbay filed against him related to the land dispute. The MTC denied the motion based on lack of jurisdiction over David. The Supreme Court ruled that while the MTC erred in stating it lacked jurisdiction, it did not abuse its discretion in denying the motion as it lacked merit.
This case discusses a land dispute between David and Agbay over 600 square meters of land in Oriental Mindoro that David bought in 2000 and later found out was public land. In 2011, David filed a motion for re-determination of probable cause with the MTC regarding a criminal complaint for falsifying documents that Agbay filed against him related to the land dispute. The MTC denied the motion based on lack of jurisdiction over David. The Supreme Court ruled that while the MTC erred in stating it lacked jurisdiction, it did not abuse its discretion in denying the motion as it lacked merit.
This case discusses a land dispute between David and Agbay over 600 square meters of land in Oriental Mindoro that David bought in 2000 and later found out was public land. In 2011, David filed a motion for re-determination of probable cause with the MTC regarding a criminal complaint for falsifying documents that Agbay filed against him related to the land dispute. The MTC denied the motion based on lack of jurisdiction over David. The Supreme Court ruled that while the MTC erred in stating it lacked jurisdiction, it did not abuse its discretion in denying the motion as it lacked merit.
This case discusses a land dispute between David and Agbay over 600 square meters of land in Oriental Mindoro that David bought in 2000 and later found out was public land. In 2011, David filed a motion for re-determination of probable cause with the MTC regarding a criminal complaint for falsifying documents that Agbay filed against him related to the land dispute. The MTC denied the motion based on lack of jurisdiction over David. The Supreme Court ruled that while the MTC erred in stating it lacked jurisdiction, it did not abuse its discretion in denying the motion as it lacked merit.
*issue and rationale focus entirely on the topic of jurisdiction* ensued. ● June 3, 2008 - CENRO rejected David’s Villarama, JR., J. MLA, ruling that his reacquisition of citizenship did not cure the defect of his MLA I. Issue: (citizenship defect), making it void ab initio. ● W/N the MTC properly denied petitioner’s ● 2010 - Information for Falsification of Public motion for re-determination of probable Document and a warrant of arrest were cause on the ground of lack of jurisdiction issued against David. over the person of the accused. NO. ● Feb. 11, 2011 - petitioner filed an Urgent Motion of Re-Determination of Probable II. Relevant Facts: Cause which the MTC denied on the ● 1974 - Petitioner, Renato David, migrated to ground of lack of jurisdiction over the Canada and became a naturalized Canadian person of the accused and for the lack of citizen. But upon his retirement, he went merit. MTC reasoned that this is because back to the PH with his wife. the crime was committed on 2007, during ● 2000 - David and wife bought a 600sqm lot this year, David was still a Canadian citizen. in Tambong, Gloria, Oriental Mindoro, and ● David elevated the case to the RTC and built a residential house there. asserted that, jurisdiction over the person ● 2004 - They found out that the portion where of an accused cannot be a pre-condition they built their house on is public land and for the re-determination of probable case part of the salvage zone. by the court. ● April 12, 2007 - Petitioner filed a MLA ● RTC denied the petition. Petitioner argued (Miscellaneous Lease Application) for the that compelling him to return to his legal subject land and indicated, herein, that he is residence in Canada and to surrender or a Filipino citizen (even though he wasn’t yet). allow himself to be arrested under a warrant ● Respondent, Editha A. Agbay, opposed this (that he has a right to question) is application, contending that petitioner is pre-empting his right to question the validity disqualified to own this land because he is a of the said warrant of arrest against him Canadian citizen. She then filed a criminal before it was implemented—this, according complaint for falsification of public to him, was tantamount to a denial of due documents (Art. 172). process. ● Petitioner thereafter reacquired his citizenship under RA 9225 on Oct. 11, 2007 III. Rationale: (issued by Toronto Consulate of the ● OSG: In seeking an affirmative relief from Philippines). the MTC when he filed the Urgent Motion for ● As a defense, petitioner said that when he Re-determination of Probable Case, filed the MLA, he already intended t o petitioner is deemed to have submitted his reacquire his citizenship that was why he person to the said court’s jurisdiction by his already declared that he is a Filipino. He also voluntary appearance. Nonetheless, the alleged that Agbay was the one who didn’t RTC still did not make a mistake in ruling have the right to sell the land as it is public that MTC did not commit grave abuse of discretion because the motion is correctly denied by virtue of the arguments it contained. ● SC: MTC did not err in finding probable cause for falsification of public document under Art. 172, par. 1. (Relevance: warrant is valid, there is probable cause, despite the issue on jurisdiction) ● SC: Custody of the law is not required for the adjudication of reliefs other than an application of bail. According to Miranda v. Tuliao, jurisdiction over the person of the accused is deemed waived when he files any pleading seeking an affirmative relief, except in cases when he invoked the special jurisdiction of the court by impugning such jurisdiction over his person. MTC erred in stating that it lacked jurisdiction over David’s person, considering that he sought affirmative relief in filing his motion for re-determination of probable case. However, the denial of this motion is still valid since MTC did not commit grave abuse of discretion, since the motion lacks merit.
IV. Dispositive: ● Petition denied. RTC decision affirmed and upheld.