G.R. No. L-43790 - People vs. City Court of Silay

The petitioner is the People of the Philippines, represented by the City Fiscal of Silay City, Marcelino M. Paviera, and private prosecutors from the Law Offices of Hilado, Hagad & Hilado.
The respondents are Ernesto de la Paz, Pacifico Senecio, Jr. y Sebusa, Romeo Millan y Delejero, and Wilfredo Jochico y Magalona, charged with falsification by private individuals and use of falsified documents under Paragraph 2, Article 172 of the Revised Penal Code.
The case arose from alleged falsification of sugar cane weight report cards (tarjetas) on January 4, 1974, at Hawaiian-Philippine Company, Silay City.

Ernesto de la Paz, overseer of Hacienda Malisbog, and co-accused, scalers Pacifico Senecio Jr., Romeo Millan, and Wilfredo Jochico, allegedly conspired to alter the weight reports of sugarcane in cane cars Nos. 1686, 1743, and 1022.
The original total actual weight was 22.005 tons, but the falsified report showed 27.160 tons, inflating the weight by 5.155 tons.
The falsification reportedly caused damage amounting to P618.19 to the Hawaiian Central and other cane planters.

The prosecution introduced evidence showing the original and substituted tarjetas with different sugar cane weights.
Original tarjetas (Exhibits B-1, C-1, D-1) reflected lower weights, while substituted tarjetas (Exhibits B, C, D) showed higher weights.
The substitution was not submitted to the laboratory but directly submitted to the laboratory section, as testified by PC SSgt. Rogelio Sevilla.

After the prosecution rested, the respondents moved for dismissal on insufficiency of evidence grounds.
Respondent court (City Court of Silay), by Judge Reynaldo M. Alon, granted the dismissal on December 19, 1975.
The court reasoned that the act of substituting tarjetas was not enumerated as an act of falsification under Article 171, R.P.C., and no falsified document thus existed.
The court emphasized the principle of strict construction of penal laws in favor of the accused and ruled the acts, though morally wrong, were not criminally punishable under the charged statute.

The People filed a Petition for Review to set aside the dismissal and reinstate the case.
The Office of the Solicitor General, after resolution, supported the People’s petition.
Respondents opposed the petition, arguing the dismissal was proper and invoking the plea of double jeopardy if retried.

Whether the substitution of sugar cane weight report cards (tarjetas) constitutes falsification under Paragraph 2, Article 172 of the Revised Penal Code.
Whether the dismissal of the case by the trial court, after the prosecution rested, constitutes an acquittal that bars further prosecution due to double jeopardy.
Whether the plea of double jeopardy is waived by the respondents by moving for dismissal of the case after prosecution rested.
Whether the appellate court can reverse the trial court’s dismissal without violating double jeopardy rules.