Facts:

The case involves Silvestre Caniza as the petitioner against the People of the Philippines and Hon. Jaime Agloro, the presiding judge of Branch XXIII of the Court of First Instance of Manila. The events leading to this case began on March 20, 1974, when an Information was filed by the Assistant City Fiscal of Manila against Caniza for the falsification of public documents, allegedly committed on November 5, 1968. On May 24, 1974, Caniza filed a Motion to Quash, arguing that the allegations did not constitute an offense and that the information contained legal justifications. The trial court granted this motion and dismissed the case on November 27, 1974. The Fiscal's subsequent undated Motion for Reconsideration was denied on April 3, 1975.

On June 13, 1979, a second Information was filed against Caniza, charging him with a similar offense. Caniza moved to quash this second Information on the grounds of prescription, double jeopardy, and insufficiency of the allegation...

Facts:

Background of the Case

• On November 5, 1968, petitioner Silvestre Caniza was alleged to have committed the crime of falsification of public documents.
• The offense related to the preparation, forging, and falsification of public documents, as evidenced by subsequent criminal charges and alleged discrepancies regarding property ownership.

Filing and Dismissal of the First Information

• On March 20, 1974, an Information (Criminal Case No. 16879) was filed by the Assistant City Fiscal of Manila with Branch 23 of the then Court of First Instance of Manila, charging Caniza with falsification of public documents.
• On May 24, 1974, petitioner Caniza filed a Motion to Quash, arguing that:
• The allegations in the Information did not constitute an offense;
• Even if true, the averments would amount to a legal excuse or justification.
• The trial court granted the Motion to Quash on November 27, 1974, dismissing Criminal Case No. 16879 against petitioner Caniza.
• The Fiscal subsequently filed an undated Motion for Reconsideration of the dismissal, which was denied on April 3, 1975.

Filing of the Second Information and Subsequent Proceedings

• On June 13, 1979, a second Information (Criminal Case No. 46768) was filed, charging petitioner Caniza with substantially the same offense as in the first Information.
• On June 29, 1979, petitioner Caniza again moved to quash the second Information on three grounds:
• The offense charged had already prescribed under the law;
• The filing of the second Information exposed him to double jeopardy since the same offense was being charged again;
• The allegations in the second Information did not constitute an offense.
• On November 27, 1979, the respondent judge issued an Order denying both the motion to quash and the motion to confiscate bond, and set the arraignment for January 9, 1980, at 8:30 a.m.
• On March 20, 1980, petitioner’s Motion for Reconsideration was again denied, with the respondent judge rescheduling the arraignment.

Petition Before the Supreme Court

• Petitioner Caniza filed a Petition for Prohibition and Certiorari on May 8, 1980, raising three issues:
• Whether the offense charged under the second Information had already prescribed;
• Whether the filing of the second Information constituted double jeopardy by subjecting him to punishment for the same offense again;
• Whether the allegations in the second Information were sufficient to establish an offense.
• The petition sought to challenge the orders of the lower court dated November 27, 1979, and March 20, 1980.

Issue:

Prescription of the Offense

• Whether the alleged crime of falsification of public documents, committed on November 5, 1968, prescribed within the ten-year period specified in Article 90 in relation to Article 172 of the Revised Penal Code.
• The computation of the prescriptive period considering the lapse between the alleged commission of the offense and the filing dates of the first and second Information, as well as the impact of the Fiscal’s Motion for Reconsideration.

Double Jeopardy

• Whether filing the second Information subjected petitioner Caniza to a second prosecution for the same offense, thereby invoking the defense of double jeopardy.
• Whether the dismissal of the first Information, being the result of a Motion to Quash filed by the accused himself, led to a waiver of the right to double jeopardy, as outlined in Section 9 of Rule 117 of the Rules of Court.

Sufficiency of the Allegations

• Whether the allegations in the second Information, in form and substance, were sufficient to constitute an offense.
• Whether any purported defects in the second Information could be properly raised in the trial rather than as preliminary issues.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)