Title
People vs. Bacolod
Case
G.R. No. L-2578
Decision Date
Jul 31, 1951
Bacolod, convicted for reckless imprudence causing injury, faced a second charge for public disturbance from the same act. SC ruled no double jeopardy, as offenses were distinct.
A

Case Digest (G.R. No. L-2578)

Facts:

  • Proceedings in the Court of First Instance of Cebu
    • On September 10, 1948, Ladislao Bacolod pleaded guilty to an information alleging serious physical injuries through reckless imprudence committed on February 21, 1948, in Santa Fe, Cebu.
    • The first information charged that, by reckless imprudence, Bacolod fired a sub-machine gun and wounded Consorcia Pasinio, causing injuries requiring medical attendance and incapacitating her for over 30 days but less than 90 days.
  • Subsequent information and motion to quash
    • Bacolod was arraigned in a separate case, on the same date and place, for causing a public disturbance: wilfully firing a sub-machine gun at a town fiesta dance, wounding Pasinio and creating panic.
    • Counsel de oficio moved to quash the second information on grounds of double jeopardy, asserting that prosecution was barred by the prior guilty plea to the first information.
    • The trial court granted the motion to quash the second information, and the People appealed.

Issues:

  • Whether the second information charging public disturbance is the same offense as the first information charging serious physical injuries through reckless imprudence, thus barred by double jeopardy.
  • Whether Section 9, Rule 113 of the Rules of Court (prohibiting prosecution for an offense necessarily included in a former charge) requires dismissal of the second information.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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