Wednesday, May 12, 2021

MEG PALER...19/20

 

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.

 

Answer: Yes, Cruz iscorrect with his contention that the 2nd case should be dismissed since it is double jeopardy.....0

 

Under the law, any person who possess unlicensed firearm shall be punished by the law if there was no other crime committed. In the case at bar, the crime was committed in violation to COMELEC Gun Ban so the case of illegal possession of firearm can only be used as an aggravating circumstance to the 1st case but not as a separate case.

 

This is the same with the Agote doctrine.

 

 

2.    NelinaAcas 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.

 

Answer:

I will not grant her motion for dismissal on the 2nd case as it is not double jeopardy.

 

In the case at bar, the filing of two sets of cases against Acas under BP 22 and under RPC does not constitute double jeopardy. Although they have the same or identical facts done by the same person, Acas, but according to the law of double jeopardy, prosecution for the same offense is not prohibited but what is not allowed is prosecuting for the same mistake.

 

In the case at bar, there were 2 identical facts but there are 2 offenses, hence the filing of 2 separate cases can prosper without 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.

 

Answer: Yes, Santos is correct. Under the law, no person shall be charged twice for the same offense. In the case at bar, he violated the municipal ordinance and he can use this to plea to file a motion to quash the second case of theft under the RPC.

 

This is the same of the Relova case, where there were two identical offenses filed separately under violation of the ordinance and against the RPC.

 

Although Relova was acquitted on the 1st case due to prescription, he is also not liable for the 2nd case filed under RPC as it is against the ground of 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.

 

Answer: Yes, the two charges will push through as it will not violate her constitutional right against jeopardy.

 

Same contention, explanation and application of law in number 2.

 

Cruz can be prosecuted for the same offense but different cases. 1st violation is under a special law of PCA and he next is theft under RPC, but double jeopardy is not applicable....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.

 

Answer: No, Luis Santos’ contention is not correct that the refiling of the same case will put him in jeopardy.

 

In the case at bar, double jeopardy does not apply as the requisites are not met. The essential elements of double jeopardy are:

1.    There must be a valid complaint

2.    It must be filed in a correct court of jurisdiction

3.    The accused has pleaded on the charge

4.    The accused has been convicted / acquitted or the case has been dismissed or it has been withdrawn without the consent of the accused

In the case at bar, it was the complaint before the Prosecutor was dismissed during the preliminary investigation and was dismissed the due to the absence of the witnesses, and its not the trial court. On this stage, there was no valid complaint that can be be brought to proper court and the dismissal of the case by the Prosecutor is not considered as acquittal. So, there was no first jeopardy to start with and so the refiling of the case is not a violation of his constitutional right. So the refiling of the case can prosper without double jeopardy...5

 

 

END OF THE QUIZ

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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 ...