JOSHUA TAN

Jurisdiction in Criminal Cases: U.S. v. Pagdayuman, 5 Phil. 265 (1905)

4. JURISDICTION; LIMITS. — The jurisdiction of a judge who presides over the court of a
judicial district shall be exercised within the territorial limits of the respective provinces. This
jurisdiction shall not be extended beyond the limits of his district nor shall the judge having such
jurisdiction try cases the cognizance of which belongs exclusively to another judge.

5. ID.; CRIMINAL CASES. — All criminal cases shall be tried at the place designated by law as
that in which the sessions of the court having jurisdiction thereof should be held. (Sec. 6 of Act
No. 140.)

6. ID.; ID.; PROCEEDINGS; NULLITY. — Proceedings in a criminal case shall be null and
void where the judge had no jurisdiction to try the same; and upon dismissal of the case new
proceedings may be commenced in the competent court. (Sec. 23, General Orders, No. 58.)

7. ID.; BRIGANDAGE. — Section 3 of Act No. 518 provides that any Court of First Instance
shall have jurisdiction to try cases for brigandage where the defendant was arrested within the
territorial limits of the court or where the prisoner accused of such crime escaped from the
provincial jail, notwithstanding the facts that the crime was not committed within such province.
Joshua Tan made this digest.

FACTS
On December 18, 1903, Pagdayuman, de Vega, Lopez, del Mundo, Gabino and Pedro delos
Santos were charged with the crime of brigandage. The information allege that on or about April
1, 1903, and for many months prior, defendants organized a band of brigands… within the city of
Manila and within the police zone of that city for the purpose of stealing carabaos and other
personal property by means of force and violence, going the highways and roaming over the
country armed with deadly weapons, and committing other plundering acts within the city of
Manila and the police jurisdiction of that city and of the Court of First Instance thereof, contrary
to the statute in such cases made and provided.

Proceedings were commenced by the filing of an information, and on March 12, 1904, sentenced
Pagdayuman and Lopez each to 25 years’ imprisonment and Vega and del Mundo each to 20
years’ imprisonment, and each to pay the cost of suit.

The case against Gabino and Pedro de los Santos was dismissed on insufficiency of evidence.

(Long discussion on the admitted incriminating evidence against defendants). The Court held
that the accused are guilty of the crime of brigandage and should be punished under Section 1 of
Act No. 518. They voluntarily joined the band and took part in some of the acts committed by its
various sections. (But, there is another issue regarding procedure)

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JOSHUA TAN

ISSUE: W/N the criminal proceedings against defendants are valid?

RULING: YES - de Vega, Lopez. NO - Pagdayuman, del Mundo.

Although these acts were not committed within the limits of the city of Manila but in the
municipalities of the Provinces of Bulacan and Rizal, it appears that de Vega was arrested in the
vicinity of the San Lorenzo Hospital, between Tondo and Santa Cruz, and Lopez was captured in
San Francisco del Monte, Sampaloc. The CFI of Manila had therefore jurisdiction to try and
decide this case. Joshua Tan made this digest.

As to the other defendants — Pagdayuman, arrested in Caloocan, Rizal, and del Mundo, arrested
in Meycauayan, Bulacan — the CFI of this city had no jurisdiction to try them. We are therefore
of opinion that all the proceedings with respect to these two defendants were null and void and
that the case should be dismissed as to them.

Lopez and de Vega are accordingly sentenced each to 20 year’s imprisonment and to pay 1/6 of
the costs. The case in so far as Pagdayuman and del Mundo is dismissed, without prejudice, to
filing a new case.

JOSHUA TAN