Case Summary (G.R. No. 86218)
Facts of the Case
On 20 March 1974, an Information was filed against Caniza for falsification related to events dating back to 1968. Caniza moved to quash this first Information on the grounds that it did not allege a legal offense. The trial court granted his motion and dismissed the case on 27 November 1974. Subsequently, the prosecution’s motion for reconsideration of this dismissal was denied. Years later, on 13 June 1979, a second Information was filed against Caniza for substantially the same offense. Caniza moved to quash this second Information on several grounds, which were ultimately denied by the respondent judge.
Issues Raised
Caniza's petition raises three primary issues: (1) whether the charges had already prescribed, (2) whether the second Information placed him in jeopardy for the same offense twice, and (3) whether the allegations in the second Information constitute an offense.
Statute of Limitations
According to Article 90 of the Revised Penal Code, the prescriptive period for the crime of falsification of public documents committed by a private individual is ten years. The Court noted the elapsed time between the alleged commission of the offenses and the filing of the Information: 5 years, 4 months, and 16 days elapsed from the date of the offense until the filing of the first Information. Additionally, the elapsed time from the denial of the prosecutor's motion for reconsideration to the filing of the second Information was noted as 4 years, 2 months, and 12 days.
Prescription Argument Rejected
Caniza contended that the Fiscal's undated motion for reconsideration did not interrupt the prescriptive period, hence the time began to run again on 27 November 1974 when the first Information was dismissed. The Court disagreed, stating that the filing of a motion for reconsideration generally continues to suspend the prescription period until the proceedings are finalized. Even by Caniza’s theory, the total elapsed time was still within the ten-year period.
Double Jeopardy Claim
Double jeopardy is addressed under Section 9 of Rule 117 of the Rules of Court, requiring a valid complaint, a competent court, a plea from the accused, a conviction or acquittal, and that the second charge is the same as the first. The petitioner had sought dismissal of the first Information, effectively waiving his right to claim double jeopardy since he was the one i
...continue readingCase Syllabus (G.R. No. 86218)
Case Information
- Court: Supreme Court of the Philippines
- Division: Third Division
- G.R. No.: 53776
- Date: March 18, 1988
- Petitioner: Silvestre Caniza
- Respondents: People of the Philippines and Hon. Jaime Agloro, Presiding Judge, Branch XXIII, Court of First Instance of Manila
Nature of the Petition
- The petition is for Prohibition and Certiorari directed at two orders issued by Branch 23 of the then Court of First Instance of Manila:
- An Order dated November 27, 1979, denying a Motion to Quash the second Information (Criminal Case No. 46768).
- An Order dated March 20, 1980, denying the Motion for Reconsideration filed by petitioner Caniza.
Background of the Case
- On March 20, 1974, an Information was filed against Silvestre Caniza for falsification of public documents allegedly committed on November 5, 1968.
- May 24, 1974: Caniza filed a Motion to Quash, asserting that the allegations did not constitute an offense.
- November 27, 1974: The trial court granted Caniza's Motion to Quash, dismissing the case.
- The prosecution filed an undated Motion for Reconsideration, which was denied on April 3, 1975.
- On June 13, 1979, a second Information was filed against Caniza with similar allegations, resulting in the current petition.
Issues Raised by the Petitioner
The petitioner raises three key issues for consideration:
- (a) Whether the offense charged has prescribed.
- (b) Whether the filing of the second Information has placed Caniza in jeopardy of punishment for the same offense.
- (c) Wheth