THE UNITED STATES VS. ANDRES JAYME, G.R. No. L-7802

Posted: November 7, 2013 in case digests
Tags: , ,

Territorial jurisdiction in criminal cases.

Effect of defect in jurisdiction.

G.R. No. L-7802                     January 16, 1913

THE UNITED STATES, plaintiff-appellee,
vs.
ANDRES JAYME, defendant-appellant.
P.E. del Rosario and Jose A. Clarin, for appellant.
Attorney-General Villamor, for appellee.

FACTS:

–          The evidence of record in this case fully sustains the findings of the trial judge, and establishes the guilt of the defendant and appellant of the crime with which he was charged and of which he was convicted in the court below, beyond reasonable doubt.

–          The counsel contends that the accused has been placed in double jeopardy, and may be dismissed without extended discussion.

–          It appears that on a former occasion, the accused was brought to trial and convicted in the court below on an information filed by the provincial fiscal, charging the identical offense of which he was convicted in this case; that in that case, this court, on appeal, dismissed the information and all the proceedings had in the court below, on the ground that the court had no jurisdiction over the subject matter of the action

ISSUE:

–          Whether or not the trial court had jurisdiction over the case

HELD:

–          The court had no jurisdiction.

–          As cited in several jurisprudence, a conviction or acquittal before a court having no jurisdiction is, of course, like all the proceedings in the case, absolutely void, and therefore no bar to subsequent indictment and trial in a court which has jurisdiction of the offense.

–          A failure in complying any element of jurisdiction, the resulting judgement is null and void.

Crim Pro case digest team:

– Karen P. Lustica

– Carmela Dumlao

– Arline Halina

– Daniel Erika

– Sannie Mae Paronda

– Randel Bejasa

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