GR L 16688 90; (April, 1963) (Digest)
G.R. Nos. L-16688-90; April 30, 1963
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. PACITA MADRIGAL-GONZALES, (formerly Pacita M. Warns), ET AL., accused-appellees.
FACTS
Accused Pacita Madrigal-Gonzales, then administrator of the Social Welfare Administration, was charged with one count of malversation of public funds. Simultaneously, she and seven co-accused were charged in 27 separate informations for the crime of falsification of public documents. The prosecution filed an ex-parte petition for consolidation, alleging the falsifications were committed to conceal the malversation, and the cases were consolidated for joint trial in one branch. The malversation case proceeded to trial, resulting in the acquittal of Madrigal-Gonzales. Subsequently, in the consolidated falsification cases, the accused filed a motion to quash on the ground of double jeopardy, arguing that the falsifications were a necessary means to commit the malversation, constituting a single offense. The trial court granted the motion and dismissed three of the falsification cases, prompting the State to appeal.
ISSUE
Whether the dismissal of the falsification cases on the ground of double jeopardy was correct, given the accused’s prior acquittal in the malversation case.
RULING
No. The Supreme Court reversed the trial court’s order of dismissal. The legal logic is anchored on the doctrine that each falsification constitutes a separate and distinct crime from malversation, even if allegedly committed to conceal it. The Court cited established jurisprudence, including People vs. Cid and Regis vs. People, which hold that falsifications committed on different vouchers, at different dates, and for various amounts are independent offenses. They are not a necessary means of committing malversation but are separate acts executed by different voluntary actions. Consequently, acquittal in the malversation case does not bar prosecution for the multiple acts of falsification. The defense of double jeopardy requires the offenses charged to be the same in law and in fact, which is not present here. The grounds for double jeopardy were not clear and indubitable but built on mere hypothesis. The Court also denied the Solicitor General’s petition to withdraw the appeal. The cases were remanded to the trial court for further proceedings.