Title
Abalos vs. People
Case
G.R. No. 136994
Decision Date
Sep 17, 2002
Abalos faced falsification charges in Dagupan and Lingayen courts; SC upheld jurisdiction, ruled no forum shopping, and deemed multifariousness waiver valid.
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Case Digest (G.R. No. 136994)

Facts:

Background and Filing of Charges

  • On November 11, 1994, an Information for Falsification of Private Documents was filed against Braulio Abalos (accused-appellant) before the Municipal Trial Court (MTC) of Dagupan City, docketed as Criminal Case No. 22707. The charge alleged that on July 12, 1994, Abalos falsified Cash Receipts Nos. 39185, 39414, and 41775, which were submitted to the Regional Trial Court (RTC) of Lingayen, Pangasinan, in support of his Bill of Costs in Civil Case No. 15958.
  • On December 12, 1994, another Information for Falsification of Private Document was filed against Abalos before the MTC of Lingayen, Pangasinan, docketed as Criminal Case No. 10024, involving Invoices Nos. 1070 and 1071.

Procedural History

  • On June 5, 1995, Abalos pleaded not guilty during his arraignment in Dagupan MTC. He later filed a Motion to Quash, arguing lack of jurisdiction. The Dagupan MTC granted the motion on October 20, 1995, but the RTC of Dagupan reversed this decision on May 14, 1996.
  • In the Lingayen case, Abalos also filed a Motion to Quash, which was denied on September 8, 1996. He then filed a Petition for Certiorari with the RTC of Lingayen, which dismissed his petition on October 28, 1996.
  • Abalos appealed both cases to the Court of Appeals (CA), which consolidated the appeals. On August 10, 1998, the CA dismissed the appeals for lack of merit. Abalos’s Motion for Reconsideration was denied on December 14, 1998.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction: Under the Judiciary Act of 1948, municipal courts have jurisdiction over criminal offenses committed within their territorial jurisdiction. The falsification of Cash Receipts Nos. 39185, 39414, and 41775 occurred in Dagupan, while the falsification of Invoices Nos. 1070 and 1071 occurred in Lingayen. Thus, both courts had jurisdiction over the respective charges.
  2. Forum Shopping: Each falsified document constitutes a separate act of falsification. The use of multiple falsified documents in a single court proceeding does not merge the offenses into one. Therefore, filing separate complaints in different courts did not constitute forum shopping.
  3. Multifariousness of Offenses: Rule 110, Section 13 of the Rules of Court prohibits charging multiple offenses in a single information. However, Abalos failed to raise this issue during arraignment, resulting in a waiver of his right to object on this ground.

Conclusion:

The Supreme Court upheld the jurisdiction of both the Dagupan and Lingayen courts, ruled that there was no forum shopping, and found that Abalos had waived his objection to the multifariousness of offenses. The petition was denied for lack of merit.


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