Case Digest (G.R. No. L-3459)
Facts:
People of the Philippines v. Maria del Carmen et al., G.R. No. 3459, January 09, 1951, the Supreme Court En Banc, Paras, J., writing for the Court.The prosecution (the People) charged the defendants (collectively, Maria del Carmen et al.) in the Municipal Court of Manila with malicious mischief, alleging that on or about March 16, 1949 the accused "willfully, unlawfully, and feloniously remove[d] and destroy[ed]" the banguera and media agua of Felix Verzosa’s house at 406 G. Tuazon St., valued at P150.
After the People presented evidence, counsel for the defendants moved and the municipal court dismissed the case on the ground that the prosecution had failed to prove that the removal or destruction had been inspired by "resentment, rancor or desire for revenge," an essential element presumed necessary by the court for malicious mischief as charged.
The same fiscal thereafter filed a second information in the Court of First Instance (CFI) of Manila charging the defendants with coercion, alleging that by means of violence, force and intimidation the accused prevented Felix Verzosa from leaving intact his house and forcibly removed the same items (the banguera and media agua), causing P150 damage.
The defendants moved to quash the coercion information on the grounds of double jeopardy and insufficiency of...(Pro-only)
Issues:
- Does the constitutional/primitive rule against double jeopardy bar prosecution for coercion after the accused were previously prosecuted for malicious mischief arising from the same act?
- If double jeopardy applies, are the offenses charged in the two informations (malicious mischief and coercion) the same offense or sufficiently distinct to per...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)