G.R. No. 31051 , November 29, 1929
PEOPLE OF THE PHILIPPINE ISLANDS vs. SALVADOR SEGOVIA, ET AL. (Virgilio Naval, Appellant)

FACTS

Appellant Virgilio Naval was convicted of falsification of a public and official document for procuring Salvador Segovia to sign his name in entry No. 3126 of the Register of Attorneys, where the name of Jose F. Aquino had been erased. This act occurred on the same occasion as another falsification case involving appellant (People vs. Ponferrada), where a different candidate’s name was inserted into a separate entry in the same register. The trial court sentenced Naval to imprisonment, a fine, and accessory penalties.

ISSUE

Whether the prosecution and conviction of Naval for the falsification involving Segovia constitute double jeopardy or improper multiplicity of charges, given that it arose from the same occasion as another falsification case previously decided against him.

RULING

No. The Supreme Court affirmed the conviction. The falsification committed by inserting Segovia’s name into entry No. 3126 is a distinct and separate offense from the falsification in the Ponferrada case, which involved a different entry (No. 3061) and a different victim. Although both acts occurred on the same occasion and shared similar circumstances, each falsification constituted an independent criminal act. Therefore, prosecuting Naval for each separate falsification does not violate double jeopardy principles. The trial court’s judgment was found without error.