Abalos v. People
REITERATIONFacts
1. The Antecedents: Braulio Abalos was charged with two separate Informations for Falsification of Private Documents. The first Information, filed in Dagupan City, alleged that on or about July 12, 1994, Abalos, with intent to cause damage to the heirs of Roman Soriano, willfully, unlawfully, and criminally caused the production and filling of entries on Cash Receipts Nos. 39185, 39414, and 41775 of Pangasinan Photostat. He then offered these as supporting documents to his Bill of Costs in Civil Case No. 15958, falsely representing them as authentic. The second Information, filed in Lingayen, Pangasinan, involved similar allegations of falsification concerning other documents. 2. Procedural History: In the Dagupan case (Criminal Case No. 22707), the Municipal Trial Court (MTC) initially quashed the Information for lack of jurisdiction on October 20, 1995. A Motion for Reconsideration was denied. The private complainant then filed a Petition for Certiorari with the Regional Trial Court (RTC) of Dagupan City, Branch 40. On May 14, 1996, the RTC reversed the MTC's orders, asserting jurisdiction. In the Lingayen case (Criminal Case No. 10024), the MTC denied Abalos's Motion to Quash. Abalos then filed a Petition for Certiorari with the RTC of Lingayen, Pangasinan, Branch 69, which dismissed his petition on October 28, 1996. Both of Abalos's appeals from these RTC decisions were consolidated and subsequently dismissed by the Court of Appeals (CA) on August 10, 1998, for lack of merit. A motion for reconsideration was denied by the CA on December 14, 1998. 3. The Petition: This petition for review seeks to overturn the CA's consolidated decision. Petitioner Braulio Abalos argues that the CA erred in concluding that both the Municipal Trial Court of Dagupan and the Municipal Trial Court of Lingayen had jurisdiction over the respective Informations. He contends that only one crime was committed and that the filing of two separate complaints with identical supporting documents constituted forum shopping. Furthermore, he argues that even if multiple offenses were committed, the Information in the Lingayen case was dismissible for charging more than one offense, and the dismissal of the Dagupan case should have been sustained. The petition specifically raises issues regarding jurisdiction, the multiplicity of offenses, and forum shopping.
Issue(s)
Whether the Municipal Trial Court of Dagupan and the Municipal Trial Court of Lingayen have jurisdiction over the respective informations for Falsification of Private Documents. Whether the filing of separate complaints for the same offense in two different courts constitutes forum shopping. Whether the respective informations were dismissible for multiplicity of offenses merged in one information.
Ruling
The Supreme Court denied the petition for lack of merit and affirmed the consolidated decision of the Court of Appeals. The Court held that both the Dagupan and Lingayen courts have jurisdiction over their respective cases, that the acts constitute separate offenses of falsification, and that the petitioner waived his objection regarding multiplicity of offenses by failing to raise it during arraignment.
Ratio Decidendi
On the issue of jurisdiction: The Court reiterated the settled law that the venue of a criminal action is determined by the place where the offense was committed or where any of its essential ingredients took place. Citing Alfelor, Sr. vs. Intia and Lopez vs. City Judge, the Court explained that municipal courts have original jurisdiction only over offenses committed within their respective territorial jurisdictions. In this case, the Information for the Dagupan case alleged the offense was committed in Dagupan City, involving cash receipts issued by Pangasinan Photostat of Dagupan City, thus vesting jurisdiction in the Dagupan court. Similarly, the Lingayen case involved invoices allegedly committed in Lingayen, Pangasinan, vesting jurisdiction in the Lingayen court. The Court clarified that the act of falsification is committed by the signing of the document with the intent to cause damage, and whether the falsified document is later used is immaterial to the commission of the crime itself. The fact that the falsified documents were used in one court proceeding does not alter the place where the offenses of falsification were committed. On the issue of forum shopping: The Court found no forum shopping, stating that there were five separate offenses of falsification involved, with three allegedly committed in Dagupan and two in Lingayen. It was erroneous for the petitioner to argue that only one offense was committed, as there are as many acts of falsification as there are documents falsified, citing People vs. Madrigal-Gonzales. The filing of separate complaints in courts of competent jurisdiction based on the place of commission of distinct offenses does not constitute forum shopping. On the issue of multiplicity of offenses: The Court acknowledged that Section 13, Rule 110 of the Rules of Court frowns upon multiple offenses being charged in a single information. However, the Court noted that the petitioner failed to raise this specific issue during his arraignment in either the Dagupan or Lingayen courts. His failure to do so constitutes a waiver, and the objection can no longer be raised on appeal. The Court pointed out that in his Motion to Quash in Dagupan, the petitioner alleged lack of jurisdiction, and in Lingayen, he alleged forum-shopping, double jeopardy, lack of jurisdiction, and that the facts do not constitute an offense. The issue of "multifariousness of offenses alleged" was only raised before the Supreme Court, making the objection belated and without avail.
Main Doctrine
The venue of a criminal action is determined by the place where the offense was committed or where any of its essential ingredients took place. Each falsified document constitutes a separate offense, and the filing of separate informations in courts of competent jurisdiction based on the place of commission does not constitute forum shopping. Failure to raise the issue of multiplicity of offenses in the trial court constitutes a waiver.