G.R. No. 136994 - Abalos vs. People

Case Summary (G.R. No. 136994)

Factual Background

Petitioner faced two informations for falsification of private documents. The first information, filed November 11, 1994 before the Municipal Trial Court of Dagupan City and docketed as Criminal Case No. 22707, charged falsification of Cash Receipts Nos. 39185, 39414, and 41775 allegedly produced in Dagupan. The second information, filed December 12, 1994 before the Municipal Trial Court of Lingayen and docketed as Criminal Case No. 10024, charged falsification of Invoices Nos. 1070 and 1071 allegedly produced in Lingayen. The informations alleged that the documents were later offered in evidence in Civil Case No. 15958 in the Regional Trial Court of Lingayen.

Initial Plea and Motions to Quash

At arraignment on June 5, 1995 in Dagupan petitioner pleaded not guilty. He filed motions to quash in both municipal courts. On October 20, 1995 the Municipal Trial Court of Dagupan ordered quashal of Criminal Case No. 22707 for lack of jurisdiction; the denial of reconsideration followed on November 20, 1995. In Lingayen, the Municipal Trial Court denied the motion to quash in its Order of September 8, 1996.

Regional Trial Court Proceedings

Private complainant sought relief from the Dagupan municipal court’s quashal by filing a petition for certiorari with the Regional Trial Court of Dagupan City. On May 14, 1996 the RTC, Branch 40, reversed and set aside the municipal court’s October 20 and November 20 orders and returned jurisdiction to the municipal court. In Lingayen petitioner’s certiorari to the RTC, Branch 69, was dismissed on October 28, 1996.

Appeal to the Court of Appeals and Consolidation

Petitioner appealed both RTC orders to the Court of Appeals. The appeals were docketed as CA-G.R. SP No. 42482 (Dagupan matter) and CA-G.R. SP No. 43237 (Lingayen matter). Petitioner moved to consolidate the appeals on February 22, 1997; the Court of Appeals granted consolidation on April 4, 1997. The Court of Appeals promulgated its consolidated decision on August 10, 1998.

Court of Appeals Disposition

The Court of Appeals dismissed both appeals for lack of merit. It held that both the Dagupan and Lingayen municipal courts had jurisdiction because the respective falsifications occurred within their territorial jurisdictions. The appellate court found that the falsification of each document constituted a separate offense and that the subsequent use of the falsified documents in one civil proceeding did not alter where the falsifications had been committed. The CA also held that petitioner waived the objection to multiplicity of offenses by failing to raise it at arraignment.

Issues Presented to the Supreme Court

The petition to the Supreme Court raised three principal assignments of error: (a) that both municipal trial courts could not have jurisdiction over the same offense and that only one crime was committed; (b) that the filing of two informations supported by identical affidavits and annexes constituted forum shopping by complainant; and (c) that, assuming multiple offenses, the informations were multiplicious and therefore dismissible under Section 13, Rule 110 of the Rules of Court.

Parties' Contentions

Petitioner argued that the acts constituted a unified and indivisible falsification, yielding only one crime, and that duplicative filings in two courts amounted to forum shopping. He further contended that the informations were dismissible for charging more than one offense in violation of Section 13, Rule 110. The Office of the Solicitor General, representing the People, maintained that each falsified document constituted a separate act of falsification, that some acts occurred in Dagupan and others in Lingayen, and that the separate filings therefore did not amount to forum shopping.

Legal Analysis on Jurisdiction

The Court applied settled venue and jurisdiction rules that locate criminal jurisdiction in the place where the offense was committed and where any essential ingredient of the offense occurred. Relying on Alfelor, Sr. v. Intia and Lopez v. City Judge, and on Section 86 of the Judiciary Act of 1948, the Court reiterated that municipal courts have original jurisdiction only over offenses committed within their territorial jurisdiction. The Court noted that falsification is complete upon the signing of the document coupled with coetaneous intent to cause damage and that the later use of the falsified document is not an essential element of the crime. Because the informations alleged that the cash receipts were falsified in Dagupan and the invoices in Lingayen, jurisdiction in each municipal court was proper.

Legal Analysis on Multiplicity and Forum Shopping

The Court addressed multiplicity under Section 13, Rule 110 of the Rules of Court, which prohibits a complaint or information from charging more than one offense. The Court observed that where multiple documents are falsified there are as many acts of falsification as there are documents, citing People v. Madrigal-Gonzales for the proposition that use of several falsified documents on one occasion does not reduce the number of falsification acts. The Court then resolved the procedural question of waiver. It held that petitioner failed to raise the multiplicity objection at arraignment in either municipality and therefore waived the right to object on appeal.

Case Syllabus (G.R. No. 136994)

Parties and Procedural Posture

Braulio Abalos was the accused-appellant in consolidated criminal proceedings for falsification of private documents.
People of the Philippines was the respondent prosecuting the alleged falsification offenses.
The accused was charged in two informations filed in separate municipal trial courts as Criminal Case No. 22707 (Dagupan) and Criminal Case No. 10024 (Lingayen).
The Municipal Trial Court of Dagupan quashed Criminal Case No. 22707 on October 20, 1995, and denied reconsideration on November 20, 1995.
The Regional Trial Court, Branch 40, Dagupan, reversed the quashal by Order dated May 14, 1996.
The Municipal Trial Court of Lingayen denied the accused's Motion to Quash on September 8, 1996, and the Regional Trial Court, Branch 69, Lingayen, dismissed the accused's certiorari petition on October 28, 1996.
The accused appealed both rulings to the Court of Appeals which consolidated the appeals and denied relief in a decision dated August 10, 1998.
The accused filed the present petition for review from the Court of Appeals' consolidated decision, which was denied by the Supreme Court in the resolution under review.

Key Factual Allegations

The Information in Dagupan charged falsification of Cash Receipts Nos. 39185, 39414 and 41775 allegedly produced by Pangasinan Photostat in Dagupan.
The Information in Lingayen charged falsification of Invoices Nos. 1070 and 1071 allegedly issued by a Xerox copying machine in Lingayen.
The Informations alleged that the falsified receipts and invoices were subsequently offered as supporting documents to a Bill of Costs in Civil Case No. 15958, Regional Trial Court, Lingayen, Branch 7.
The Informations alleged intent to cause damage to heirs of Roman Soriano, including Evelyn C. Soriano, who was identified as the complainant.
The alleged acts of falsification occurred at different times and in different localities according to the Informations.

Lower Court Proceedings

The accused entered a plea of not guilty at arraignment in Dagupan on June 5, 1995.
The accused moved to quash both Informations on jurisdictional and other grounds before the respective municipal trial courts.
The Municipal Trial Court of Dagupan quashed the Dagupan Information for lack of jurisdiction, which was later reversed by the Dagupan RTC on certiorari.
The Municipal Trial Court of Lingayen denied the Motion to Quash and the Lingayen RTC dismissed the accused's certiorari petition.
The accused moved to consolidate his appeals before the Court of Appeals, which grant ed consolidation and subsequently dismissed both appeals for lack of merit.

Issues Presented

Whether the M T C C - Dagupan and M T C - Lingayen had jurisdiction over the respective Informations for falsification of private documents.
Whether the filing of separate but identical complaints and annexes in two different municipal courts constituted forum shopping.
Whether the informations were multiplicitous by charging more than one offense in a single information contrary to Sec. 13, Rule 110, Rules of Court.
Whether separate acts of falsification alleged in different localities constituted a single, unified offense or multiple offenses.

Contentions of the Accused

The accused contended that only one crime was committed because of a unified and indivisible criminal intent, which precluded concurrent jurisdiction by two municipal courts.
The accused argued that filing identical complaints in two different courts amounted to forum shopping by the complainant and the People.
The accused asserted that the Informations were dismissible for multiplicity of offenses by charging several falsifications in a single information contrary to Sec. 13, Rule 110.

Contentions of the Respondent

The Office of the Solicitor General argued that both municipal courts properly assumed jurisdiction because the alleged falsifications consisted of