Magdalena Sangalang vs. People of the Philippines and Hon. Carmelino G. Alvendia, Judge of the Court of First Instance of Manila
**Facts:**
1. **Initial Charge:**
– On April 18, 1952, Magdalena Sangalang, Enriqueta Pascoquin, Nicodemus Domingo, and Bayani de la Cruz were charged with qualified theft for allegedly taking and carrying away 15,000 empty jute bags belonging to the National Rice and Corn Corporation (NA-RIC).
– This case was docketed as Criminal Case No. 18659 in the Court of First Instance of Manila.
2. **Motion to Dismiss:**
– After the prosecution presented its case, all the accused filed motions for dismissal due to insufficiency of evidence.
– Judge Francisco E. Jose dismissed the case against Magdalena Sangalang and Bayani de la Cruz with costs de oficio.
3. **Subsequent Charge and Dismissal:**
– On September 3, 1957, the same assistant city fiscal who previously filed the charge, filed a new information charging Sangalang and Leandro Castelo with estafa involving the same incident from January 15, 1952.
– This new case was docketed as Criminal Case No. 41366.
– Upon arraignment, Sangalang pleaded “not guilty” but later withdrew the plea to file a motion to quash on the ground of double jeopardy.
– The motion to quash was granted, and the case was dismissed as against her with one-half of the costs de oficio on March 14, 1958. This order became final and was not appealed.
4. **Third Charge:**
– On December 29, 1958, a third information was filed against Sangalang in Criminal Case No. 46860 in the Court of First Instance of Manila for the same offense of estafa covered in Criminal Case No. 41366.
– Sangalang’s counsel filed a motion to quash invoking double jeopardy, but Judge Carmelino G. Alvendia denied the motion and ordered her arraignment.
– Sangalang’s motion for reconsideration was also denied.
5. **Supreme Court Involvement:**
– Sangalang filed a petition for prohibition with the Supreme Court to restrain Judge Alvendia from proceeding with the trial in Criminal Case No. 46860.
**Issues:**
1. **Double Jeopardy:**
– Whether the third charge for estafa in Criminal Case No. 46860 constitutes double jeopardy given the previous dismissals on the same ground in Criminal Case Nos. 18659 and 41366.
**Court’s Decision:**
1. **Double Jeopardy Upheld:**
– The Supreme Court ruled in favor of Sangalang, emphasizing that the motion to quash on the ground of double jeopardy was valid.
– The court noted that an order sustaining a motion to quash on the ground of double jeopardy bars another prosecution for the same cause (Sec. 8, Rule 113, Rules of Court).
– Since the motion to quash in Criminal Case No. 41366 was sustained and became final, it constituted a double jeopardy bar against the new information filed in Criminal Case No. 46860.
– The Court found that Judge Alvendia committed grave abuse of discretion by not dismissing the information in Criminal Case No. 46860.
**Doctrine:**
– **Double Jeopardy Doctrine:**
– Once a defendant’s motion to quash on the grounds of double jeopardy is sustained and the order becomes final, it constitutes a bar to any subsequent prosecution for the same offense. (Sec. 8, Rule 113, Rules of Court)
– Relevant cases: People vs. Petilla, 92 Phil. 395.
**Class Notes:**
– **Double Jeopardy Elements:**
– Filing of a proper charge.
– A competent court.
– The defendant was acquitted, convicted, or the case was dismissed without the consent of the accused.
– **Key Provisions:**
– Sec. 8, Rule 113 of the Rules of Court: A ruling on double jeopardy constitutes a bar to subsequent prosecutions for the same offense.
**Historical Background:**
– During the early 1950s, the Philippine legal system grappled with issues of procedural justice and safeguards against multiple punishments for the same offense.
– This case underscores the judiciary’s role in ensuring fairness and justice, protecting individuals from repeated prosecutions and undue state harassment.
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