G.R. No. 215568 - Rivera vs. Genesis Transport Service, Inc.

The case involves the United States as Plaintiff and Appellee against Roman Infante and Tomas Barreto as Defendants and Appellants.
It is intimately connected with a similar case (No. 11449) decided previously, with many of the observations and reasons in that case bearing upon the issues in the present one.

The appellants were previously convicted for falsification of a pawn ticket issued by the Monte de Piedad.
Evidence indicated that the defendants altered the original description of the pawned article on the pawn ticket, substituting it with an article of substantially higher value.
The falsified pawn ticket was then presented at the pawnshop of the complaining witness to secure a loan far exceeding the true value of the pawned article.

In the present case, the same appellants were convicted for the falsification of another pawn ticket issued by the Monte de Piedad.
The evidence demonstrated that this second pawn ticket was falsified at or about the same time and in a manner substantially similar to the first ticket’s falsification.
Both falsified pawn tickets were subsequently used at the pawnshop of the complaining witness with the objective of procuring an unlawfully high loan amount relative to the actual value of the originally pawned items.

The appellants contended that because both pawn tickets were falsified concurrently and used for the same fraudulent purpose, only one unified crime was committed.
The argument focused on the assertion that the two falsifications should not be treated as separate consummated offenses but rather as a single criminal act.

Whether the falsification of each pawn ticket constitutes a distinct and separate criminal offense under the law.
Whether the acts, although executed at the same time and for the same purpose, can coagulate into a single offense or must be treated independently.

The appellants argued that being charged and convicted separately for what they claim is essentially one act amounts to double jeopardy.
The issue is whether the plea of double jeopardy is applicable given that two distinct falsifications occurred, each with independent legal consequences.

Whether under article 304 of the Penal Code the crime of falsification of a private document is complete at the moment of falsification regardless of subsequent use.
Whether the intent to defraud a third party, which remains consistent in both incidents, influences the legal interpretation of the offenses as separate crimes.