G.R. No. 221356 - Umali vs. Hobbywing Solutions, Inc.

Petitioners: People of the Philippines and Asst. Provincial Fiscal F. Visitacion, Jr.
Respondents: Honorable Midpantao L. Adil, Presiding Judge, Court of First Instance (Branch II), Iloilo, and Margarito Fama, Jr.
The case involves two criminal cases arising from the same incident:

Criminal Case No. 3335 filed at the Municipal Court of Janiuay, Iloilo charging Margarito Fama, Jr. with slight physical injuries.
Criminal Case No. 5241 filed at the Court of First Instance of Iloilo charging Margarito Fama, Jr. with serious physical injuries.

On April 12, 1975, in Janiuay, Iloilo, Margarito Fama, Jr., allegedly assaulted Miguel Viajar by hurling a stone that hit Viajar’s right cheek.
Initial medical certificate in Case No. 3335 indicated injuries would require medical attendance from 5 to 9 days barring complications, constituting slight physical injuries.
Case No. 3335 was filed on April 15, 1975, and Fama, Jr. pleaded not guilty on July 7, 1975.
On June 8, 1975, Miguel Viajar filed a letter-complaint with the Provincial Fiscal charging serious physical injuries against Margarito Fama, Jr. and others, arising from the same incident.
After preliminary investigation, an information for serious physical injuries was filed against Margarito Fama, Jr. only in Case No. 5241 on July 28, 1975.
The information in Case No. 5241 alleged additional injury: a permanent scar and deformity on the right face, aside from injuries requiring medical attendance (5 to 9 days).

Fama, Jr. filed a motion to defer proceedings and claimed double jeopardy, asserting Case No. 3335 had already been filed and he had pleaded not guilty there.
The Fiscal opposed the motion; both parties were required to file memoranda on the double jeopardy issue.
The prosecution sought dismissal of Case No. 3335, but the municipal court did not act favorably, instead setting the case for hearing.
Due to repeated postponements requested by the prosecution, the municipal court dismissed Case No. 3335 on September 1, 1975, citing violation of accused’s right to a speedy trial.
On September 22, 1975, the Court of First Instance dismissed Criminal Case No. 5241 on grounds of double jeopardy, relying on the dismissal of Case No. 3335 and the ruling in People vs. Silva.
The prosecution’s motion for reconsideration was denied by order dated October 14, 1975.

Whether the dismissal of Criminal Case No. 5241 on the ground of double jeopardy was proper, given the prior dismissal of Criminal Case No. 3335, both arising from the same incident.
Whether the additional allegation of permanent scar and deformity in Case No. 5241 constitutes a supervening element or a new and distinct offense, thus allowing prosecution despite the earlier case.
Whether the right of the accused to be protected against double jeopardy was violated by the prosecution pursuing Case No. 5241 after the initiation and dismissal of Case No. 3335.