Title
Caniza vs. People
Case
G.R. No. 53776
Decision Date
Mar 18, 1988
A 1974 falsification case against Silvestre Caniza was dismissed, refiled in 1979, and challenged on prescription, double jeopardy, and sufficiency of allegations. The Supreme Court ruled the offense was within the prescriptive period, no double jeopardy occurred, and the Information was sufficient, remanding the case for trial.
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Case Digest (G.R. No. 53776)

Facts:

Initial Filing and Motion to Quash

  • On 20 March 1974, an Information (Criminal Case No. 16879) was filed by the Assistant City Fiscal of Manila against petitioner Silvestre Caniza for falsification of public documents, allegedly committed on 5 November 1968.
  • On 24 May 1974, Caniza filed a Motion to Quash, arguing that the allegations in the Information did not constitute an offense and that the Information contained averments that, if true, would constitute a legal excuse or justification.
  • On 27 November 1974, the trial court granted the Motion to Quash and dismissed the case. The Fiscal filed an undated Motion for Reconsideration, which was denied on 3 April 1975.

Second Filing and Motion to Quash

  • On 13 June 1979, a second Information (Criminal Case No. 46768) was filed, charging Caniza with substantially the same offense.
  • On 29 June 1979, Caniza again filed a Motion to Quash, arguing that (1) the offense had prescribed, (2) the quashal of the first Information was on the merits, and (3) the allegations in the second Information did not constitute an offense.
  • On 27 November 1979, the trial court denied the Motion to Quash and set the case for arraignment. Caniza’s Motion for Reconsideration was also denied on 20 March 1980.

Petition to the Supreme Court

  • On 8 May 1980, Caniza filed a Petition for Prohibition and Certiorari with the Supreme Court, raising three issues: (1) whether the offense had prescribed, (2) whether the filing of the second Information placed him in double jeopardy, and (3) whether the allegations in the second Information constituted an offense.

Issue:

  1. Prescription of the Offense: Whether the crime of falsification of public documents had already prescribed by the time the second Information was filed.
  2. Double Jeopardy: Whether the filing of the second Information placed Caniza in double jeopardy.
  3. Sufficiency of the Information: Whether the allegations in the second Information constituted an offense.

Ruling:

The Supreme Court dismissed the Petition for Prohibition and Certiorari, affirming the trial court’s Orders dated 27 November 1979 and 20 March 1980. The case was remanded to the trial court for trial on the merits.

Ratio:

  1. Prescription of the Offense:

    • Under Article 90 and Article 172 of the Revised Penal Code, the crime of falsification of public documents by a private individual prescribes in 10 years.
    • The prescriptive period is interrupted by the filing of a complaint or information and resumes when proceedings terminate without conviction or acquittal.
    • The Court calculated that 9 years, 6 months, and 28 days of the prescriptive period had elapsed by the time the second Information was filed, leaving the offense still within the prescriptive period.
    • The Fiscal’s Motion for Reconsideration tolled the running of the prescriptive period, and even if it did not, the total elapsed time would still be 9 years, 11 months, and 5 days, which is within the 10-year limit.
  2. Double Jeopardy:

    • For double jeopardy to apply, the following requisites must be met: (1) a valid complaint or information, (2) a court of competent jurisdiction, (3) the accused has pleaded to the charge, (4) the accused has been convicted, acquitted, or the case dismissed without his express consent, and (5) the second offense is the same as the first.
    • In this case, the first Information was dismissed upon Caniza’s Motion to Quash, which was with his express consent. This dismissal did not bar another prosecution for the same offense, as Caniza effectively waived his right against double jeopardy by preventing the trial court from rendering a judgment on the merits.
    • The dismissal of the first Information was not on the merits and did not amount to an acquittal, as it was based on the insufficiency of the allegations in the Information.
  3. Sufficiency of the Information:

    • The Court agreed with the trial court that the second Information was sufficient in form and substance to sustain a conviction for the crime of falsification of public documents.
    • Caniza’s arguments regarding the insufficiency of the allegations were matters to be raised and determined during the trial.

Conclusion:

The Supreme Court held that the offense had not prescribed, that Caniza was not placed in double jeopardy, and that the second Information was sufficient to sustain a conviction. The Petition was dismissed, and the case was remanded for trial on the merits.


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