Calme v. Court of Appeals

G.R. No. 116688 (August 30, 1996)

Wenefredo Calme's appeal on a murder charge was denied; SC upheld proper jurisdiction during transit.

Facts:

Petitioner Wenefredo Calme, along with four other individuals, was accused of murdering Edgardo Bernal by allegedly throwing him overboard from the M/V "Cebu City," an interisland passenger ship owned by William Lines, Inc. The incident occurred on the night of May 12, 1991, while the vessel was en route from Ozamis City to Cebu City. Following the incident, Calme filed a motion to quash the information for murder, arguing that the Regional Trial Court (RTC) of Oroquieta City lacked jurisdiction over the case. He contended that the crime occurred while the vessel was in transit, and thus, the proper venue should be Siquijor, as indicated by the Marine Protest filed by the ship's captain, Elmer Magallanes, which stated that the ship was 8.0 miles off Minalonan Point, Siquijor Island when the captain received the report of a passenger jumping overboard.

The RTC, presided over by Judge Celso Conol, denied Calme's motion to quash, asserting that the court had jurisdiction over the case. Calme subsequently filed a petition for certiorari and prohibition with the Court of Appeals, which was dismissed in a decision dated December 10, 1993. His motion for reconsideration was also denied on July 14, 1994. Consequently, Calme appealed to the Supreme Court, raising the sole issue of whether the RTC of Oroquieta City had jurisdiction over the murder charge against him.

Legal Issues:

The primary legal issue in this case was whether the RTC of Oroquieta City had jurisdiction over the murder charge against Calme, given that the alleged crime occurred while the vessel was in transit and the specific location of the incident was disputed.

Arguments:

  • Petitioner’s Argument: Calme argued that the applicable provision for determining jurisdiction was Section 15(a) of Rule 110 of the Revised Rules of Court, which states that criminal actions should be instituted in the court of the municipality where the offense was committed. He claimed that since the exact location of the crime was known (8.0 miles off Minalonan Point, Siquijor), the proper venue should be Siquijor. He further contended that even if Section 15(c) applied, Oroquieta City should still be excluded as a proper venue because the reckoning point for determining venue should be the first port of entry or the municipalities through which the ship passed after the crime was discovered.

  • Respondent’s Argument: The RTC and the Court of Appeals maintained that the jurisdiction was properly vested in the RTC of Oroquieta City. They argued that the crime occurred while the vessel was in transit, and thus, Section 15(c) of Rule 110 applied, allowing the case to be tried in the proper court of the first port of entry or any municipality through which the vessel passed during its voyage. They asserted that the Marine Protest did not conclusively establish the exact location of the crime, and the interpretation of "in transit" supported the jurisdiction of the Oroquieta RTC.

Court’s Decision and Legal Reasoning:

The Supreme Court upheld the decision of the Court of Appeals, affirming the jurisdiction of the RTC of Oroquieta City over the murder charge against Calme. The Court reasoned that the exact location of the crime was not definitively established by the Marine Protest, which only indicated that the vessel was near Siquijor when the captain received the report of the incident. The Court emphasized that the term "in transit" refers to the vessel being on its way from one place to another, and thus, the applicable provision was Section 15(c) of Rule 110, which allows for jurisdiction in the proper court of the first port of entry or any municipality through which the vessel passed during its voyage.

The Court further clarified that the previous Act No. 400, which Calme relied upon, had been amended and was not applicable under the current rules. The Court highlighted the principle of statutory construction, stating that when the language of a law or rule is clear and unequivocal, it must be given its literal meaning without interpretation. Therefore, the Court concluded that the RTC of Oroquieta City had proper jurisdiction over the case.

Significant Legal Principles Established:

  1. Jurisdiction in Maritime Crimes: The case clarifies the jurisdictional rules applicable to crimes committed on board vessels in transit, specifically under Section 15(c) of Rule 110 of the Revised Rules of Court.

  2. Statutory Construction: The decision underscores the principle that clear and unequivocal provisions of law must be interpreted according to their literal meaning, without reliance on prior statutes that have been amended or superseded.

  3. Definition of "In Transit": The Court's interpretation of "in transit" establishes that it encompasses any point during the vessel's journey, reinforcing the jurisdictional authority of courts along the vessel's route.