Wednesday, May 12, 2021

BANAS ROVYTTE...24/25

 

1.      Jose Cruz was caught carrying an unlicensed firearm in one of the checkpoints established in Sergio Osmena, while he was riding his car going to Dipolog. He was frisked and the firearm on his waistline was confiscated after he was made to disembark from his car. He was then charged for two offenses: (1) for carrying a firearm during an election gun ban (2) for carrying a firearm without a license under R. A. 10591. He was arraigned on both charges, and after that he filed a motion to dismiss the charge under R.A. 10591 as it is a violation of his right against double jeopardy. Decide, whether he is correct in his contention. Explain.

 

No. Cruz contention was wrong. Double Jeopardy refers to jeopardy of punishment for the same offense. In order that protection against double jeopardy will be obtain these following requisites must concur:

 

1)      A first jeopardy must have attached prior to the second;

2)      The first jeopardy must have been validly terminated; and

3)      The second jeopardy must be for the same offense or the second offense includes or is necessarily included in the offense charged in the first information, or is an attempt to commit the same or frustration thereof.

In this case, none of the following requisites was present.  The two jeopardy being charged against the accused was filed at the same time. Neither of the two offenses were validly  terminated of a different time as the both are still pending. Lastly, the two offenses being charged was not of the same offense. Therefore, the Cruz was wrong on his claim that his right against double jeopardy was violated....5

 

2.      Nelina Acas obtained 20 sacks of rice from the store of Juan Casis. She issued a PNB check for the sum of 40,000 pesos as payment of said rice. Eventually, the check bounced for insufficiency of funds. Juan Casis filed two cases against her: First for violating BP 22 and then another one for Estafa under the Revised Penal Code. She was arraigned on both charges, trial proceeded. She was acquitted for the Estafa charge for insufficiency of evidence. Meanwhile the trial for BP 22 continued, and while the trial was going on, she filed a motion to dismiss for the reason that her acquittal in the Estafa case for the same checks which she issued, already put her on the first jeopardy and to try her for BP 22 would necessarily put her in double jeopardy. Decide whether you grant her motion to dismiss or not.

 

Anna’s contention was not correct. In order that double jeopardy may be availed the following requisites must be present:

1)      A first jeopardy must have attached prior to the second;

2)      The first jeopardy must have been validly terminated; and

3)      The second jeopardy must be for the same offense or the second offense includes or is necessarily included in the offense charged in the first information, or is an attempt to commit the same or frustration thereof.

Moreover, in order that the first jeopardy is said to have been validly attached, the following elements must concur:

1.      There must be a valid complaint or information in form and substance to sustain a conviction of the crime charged;

2.      It must be filed in a court of competent jurisdiction;

3.      The accused has been arraigned and had pleaded; and

4.      The accused was convicted or acquitted or the case was dismissed without his expressed consent.

In this case, though the first jeopardy was validly attached prior to the second offense, this was, however, not the same offense as the second offense. The first Jeopardy is a violation which is punishable under the RPC or is a mala in se while the second jeopardy is punishable under the special penal law or is a mala prohibita. Since that the two offenses charged are imposes specific and different penalties under a different statutes, therefore, anna cannot her right against double jeopardy......5

 

3.      Juan Santos put a jumper on his electrical connection to save on electricity. When this was discovered by ZANECO, a case for Violating Dipolog Ordinance (for illegal jumpers) and another one for THEFT of electricity under the REVISED Penal CODE  were filed against him. He said that this cannot be, since there is already a double jeopardy. Decide.

 

Juan Santos can claim his right against double jeopardy. Under Sec. 21 of the 1987 Constitution provides that:

Section 21. No person shall be twice put in jeopardy of punishment for the same offense. If an act is punished by a law and an ordinance, conviction or acquittal under either shall constitute a bar to another prosecution for the same act.

The second sentence of the above provision is applicable to this case. In the sentence it is clear that double jeopardy can be claim if the charged is of the same act though it is punishable under a law and an ordinance.  Since the two charges against Santos are of the same act therefore, Santos can claim that this would be a violation of his right against double jeopardy....4

 

4.      Mario Cruz was caught by the police officers cutting coconut trees without permit from the PCA. It was also learned that he is not the owner of these coconut trees as they are owned by Maria Sy. Maria Sy filed a complaint for theft of coconut trees against him. The PCA also filed a case for illegal cutting of coconut trees (without PCA permit). Will the two charges push through without violating her rights against double jeopardy? Explain.

The charges against him is not a violation of his right against double jeopardy. In order that double jeopardy may be availed the following requisites must be present:

1.      A first jeopardy must have attached prior to the second;

2.      The first jeopardy must have been validly terminated; and

3.      The second jeopardy must be for the same offense or the second offense includes or is necessarily included in the offense charged in the first information, or is an attempt to commit the same or frustration thereof.

In this case, none of the following requisites was present.  The two offenses charged against Maria are both filed of the same time so there is no prior jeopardy that was validly attached. Neither of the two offenses were validly terminated as the both are still pending. Lastly, the two offenses being charged was not of the same offense since that the theft is covered under the RPC while illegal cutting of coconut trees is a violation under the special penal laws. Therefore, Maria’s right against double jeopardy was not violated.....5

 

5.      Luis Santos is accused of murder by the police officers. The case was filed at the Prosecutor’s office which conducted the preliminary investigation. As the witnesses did not appear, the honorable prosecutor dismissed the case. After two months the witnesses appeared before the prosecutor, and after conducting the investigation, a probable cause was found against Luis Santos. Eventually, a case for murder was filed before the Regional Trial Court in Dipolog City. The accused was arraigned and pleaded not guilty as charge. After that Luis Santos filed a motion to dismiss the case, considering that it was dismissed previously by the Hon. Prosecutor, and the refiling of the same already put him in double jeopardy. Is he correct? As judge will you dismiss the case against him? Explain your answer.

No. If I were the judge I will not dismiss the case. In order that double jeopardy may be availed the following requisites must be present:

1.      A first jeopardy must have attached prior to the second;

2.      The first jeopardy must have been validly terminated; and

3.      The second jeopardy must be for the same offense or the second offense includes or is necessarily included in the offense charged in the first information, or is an attempt to commit the same or frustration thereof.

Moreover, in order that the first jeopardy is said to have been validly attached, the following elements must concur:

1)      There must be a valid complaint or information in form and substance to sustain a conviction of the crime charged;

2)      It must be filed in a court of competent jurisdiction;

3)      The accused has been arraigned and had pleaded; and

4)      The accused was convicted or acquitted or the case was dismissed without his expressed consent.

In this case, the first jeopardy was not validly attached since that it lacks of the 2nd and 3rd requisites. The first jeopardy against santos was terminated during the conduct of the preliminary investigation, so this would mean that it was not filed in a court of competent jurisdiction nor does he was arraigned and pleaded of the charged against him. Since these had lack requisites for a first jeopardy to be validly attached prior to the second charged, therefore, it is not proper to dismiss the case on the ground of double jeopardy....5

 

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IN THE MATTER OF THE ALLEGATIONS CONTAINED IN THE COLUMNS OF MR. AMADO P. MACASAET PUBLISHED IN MALAYA DATED SEPTEMBER 18, 19, 20 AND 21, 2007. D E C I S I O N

  Republic of the Philippines SUPREME COURT Manila EN BANC A.M. No. 07-09-13-SC             August 8, 2008 IN THE MATTER OF THE ALLEGATIONS ...