Case Summary (G.R. No. 53776)

I. Case Overview

• Petitioner: Silvestre Caniza
• Respondents: People of the Philippines, Hon. Jaime Agloro (Presiding Judge, Branch XXIII, Court of First Instance of Manila)
• Date of Decision: March 18, 1988
• Nature of Petition: Petition for Prohibition and Certiorari against the Orders of the trial court.

II. Background of the Case

• An Information for falsification of public documents was filed against Caniza on March 20, 1974 (Criminal Case No. 16879).
• Caniza filed a Motion to Quash on May 24, 1974, claiming the allegations did not constitute an offense.
• The trial court granted the Motion to Quash on November 27, 1974, dismissing the case.
• Subsequent to a Motion for Reconsideration by the Fiscal, which was denied on April 3, 1975, a second Information was filed on June 13, 1979 (Criminal Case No. 46768), with similar charges against Caniza.

III. Legal Issues Raised

• The Petition raised three primary issues:
  • Whether the offense charged had prescribed.
  • Whether the second Information subjected Caniza to double jeopardy.
  • Whether the allegations in the second Information constituted an offense.

IV. Prescription of Offense

• Legal Principle: Under Article 90 and Article 172 of the Revised Penal Code, the crime of falsification by a private individual prescribes in 10 years.

• Key Definitions:

  • Prescription: The period after which legal actions can no longer be initiated.

• Important Timeframes:

  • First Information Filed: March 20, 1974 (5 years, 4 months, 16 days elapsed since the alleged offense on November 5, 1968).
  • Second Information Filed: June 13, 1979 (4 years, 2 months, 12 days elapsed after the denial of the first Information's reconsideration).
  • Total Time Elapsed: 9 years, 6 months, and 28 days by the time of the second Information filing.

• Consequences:

  • Petitioner Caniza's claim that the prescription period had expired was rejected. The court ruled that the filing of the Motion for Reconsideration interrupted the prescription period, which only resumes after termination of proceedings.

V. Double Jeopardy

• Legal Principle: Double jeopardy protects against being tried for the same offense after acquittal, conviction, or dismissal that is not based on consent.

• Requirements to Invoke:

  • A valid Complaint or Information.
  • A court of competent jurisdiction.
  • The accused must have pleaded to the charge.
  • The accused must have been convicted, acquitted, or the case must have been dismissed without their consent.

• Key Findings:

  • The dismissal of the first Information was initiated by Caniza's Motion to Quash, indicating consent to the dismissal.
  • Dismissals based on grounds questioning the sufficiency of the Information do not equate to an acquittal on the merits.

• Consequences: Caniza waived his right to assert double jeopardy by moving to quash the first Information.

VI. Sufficiency of the Second Information

• The court concluded that the second Information was sufficient in form and substance to support a conviction. The claims regarding its insufficiency were deemed matters for trial.

VII. Final Ruling

• Disposition: The Petition for Prohibition and Certiorari was dismissed. The earlier orders of the trial court (November 27, 1979, and March 20, 1980) were affirmed. The case was remanded for trial on the merits.

Key Takeaways

• The Supreme Court reaffirmed that the prescription of offenses is tolled by the filing of motions for reconsideration.
• A dismissal of a case initiated by the defendant does not bar subsequent prosecuti

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Case Syllabus (G.R. No. 53776)

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

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