Case Digest (G.R. No. 136994)
Facts:
Braulio Abalos v. People of the Philippines, G.R. No. 136994, September 17, 2002, the Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioner Braulio Abalos was charged with multiple counts of falsification of private documents after informations were filed in two municipal trial courts. On November 11, 1994 an information was filed in the Municipal Trial Court (MTCC) of Dagupan City as Criminal Case No. 22707, alleging falsification of Cash Receipts Nos. 39185, 39414 and 41775 issued by Pangasinan Photostat (Dagupan). On December 12, 1994 a separate information was filed in the Municipal Trial Court (MTC) of Lingayen as Criminal Case No. 10024, concerning Invoices Nos. 1070 and 1071 allegedly issued in Lingayen.
At arraignment in Dagupan on June 5, 1995, petitioner pleaded not guilty and, on August 7, 1995, moved to quash the Dagupan information for lack of jurisdiction. The MTCC-Dagupan granted the motion and quashed Criminal Case No. 22707 on October 20, 1995; its denial of the private complainant’s motion for reconsideration was entered on November 20, 1995. The private complainant then filed a petition for certiorari with the Regional Trial Court (RTC) of Dagupan, Branch 40, which on May 14, 1996 reversed and set aside the MTCC-Dagupan orders.
In Lingayen the trial court denied petitioner’s motion to quash on September 8, 1996. Petitioner sought certiorari relief from the RTC of Lingayen, Branch 69, which on October 28, 1996 dismissed his petition. Petitioner appealed both RTC rulings to the Court of Appeals (CA) as CA-G.R. SP No. 42482 (Dagupan) and CA-G.R. SP No. 43237 (Lingayen); the CA consolidated the appeals and, on August 10, 1998, dismissed them for lack o...(Subscriber-Only)
Issues:
- Do the MTCC-Dagupan and MTC-Lingayen have jurisdiction over the falsification offenses charged against petitioner?
- Does the filing of two separate informations supported by identical affidavits and annexes in two different municipal courts constitute forum shopping?
- Are the informations dismissible for multiplicity/duplicity of offenses charged in violation of Section 13,...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)