Case Digest (G.R. No. 110315) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Renato Cudia v. Court of Appeals, petitioner Renato Cudia was arrested on June 28, 1989 in Purok 6, Barangay Santa Inez, Mabalacat, Pampanga, by members of the 174th PC Company for allegedly possessing an unlicensed .38 caliber revolver with six live rounds. He was detained at Camp Pepito, Angeles City, and a preliminary investigation ensued. The City Prosecutor of Angeles City filed the first information (Criminal Case No. 11542) charging Cudia with illegal possession of firearms and ammunition, and he pleaded not guilty upon arraignment before Branch 60 of the Regional Trial Court (RTC), Angeles City, on August 14, 1989. During pre-trial, the court noted that the offense occurred in Mabalacat, outside its territorial jurisdiction, and ordered the case re-raffled to Branch 56. Meanwhile, on October 31, 1989, the Pampanga Provincial Prosecutor filed a second information (Criminal Case No. 11987) for the same offense and venue properly laid in Mabalacat before Branch 56. The C Case Digest (G.R. No. 110315) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Arrest and Initial Information
- On June 28, 1989, petitioner Renato Cudia was arrested in Purok 6, Barangay Santa Inez, Mabalacat, Pampanga, by members of the 174th PC Company for alleged possession of an unlicensed .38 caliber revolver with six live rounds.
- He was detained at Camp Pepito, Sto. Domingo, Angeles City, and subjected to a preliminary investigation by an investigating panel of prosecutors.
- First Information and Venue Irregularity
- The City Prosecutor of Angeles City filed the first information (Criminal Case No. 11542) charging illegal possession of firearms and ammunition, alleging the offense occurred “in the City of Angeles.”
- Upon arraignment on August 14, 1989, petitioner pleaded not guilty. At pre-trial, it was discovered the offense occurred in Mabalacat, not Angeles City; the case was re-raffled from Branch 60 to Branch 56 of the Angeles City RTC.
- Second Information, Dismissal, and Appeals
- On October 31, 1989, the Provincial Prosecutor of Pampanga filed a second information (Criminal Case No. 11987) for the same offense, raffled also to Branch 56.
- The prosecutor in CC No. 11542 moved to dismiss/withdraw the first information (granted April 3, 1990) despite petitioner’s opposition. Petitioner then moved to quash CC No. 11987 on double jeopardy grounds (denied by trial court).
- The Court of Appeals dismissed his appeal, ruling no double jeopardy, and denied reconsideration. Petitioner elevated the case to the Supreme Court.
Issues:
- Did the first information (CC No. 11542) constitute a valid complaint by a court of competent jurisdiction such that jeopardy attached?
- Was the City Prosecutor of Angeles City authorized to file the first information for an offense committed in Mabalacat, Pampanga?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)