Abalos vs. People

A court acquires territorial jurisdiction over a falsification case where the document was falsified with the coetaneous intent to cause damage, irrespective of where the falsified document was subsequently used, and each falsified document gives rise to a separate offense.

Braulio Abalos was accused of falsifying five private documents—three cash receipts from Pangasinan Photostat in Dagupan City and two invoices from Xerox Copying Machine in Lingayen, Pangasinan. These falsified documents were subsequently submitted to the Regional Trial Court of Lingayen, Branch 37, as supporting documents for a Bill of Costs in a civil case, allegedly causing damage to the adverse party, Evelyn C. Soriano. Separate informations for falsification of private documents were filed in the Municipal Trial Court of Dagupan City for the cash receipts and in the Municipal Trial Court of Lingayen for the invoices.

• The Falsified Documents: On July 12, 1994, Braulio Abalos allegedly caused the production of and filled in entries on three cash receipts (Nos. 39185, 39414, and 41775) from Pangasinan Photostat in Dagupan City, and two invoices (Nos. 1070 and 1071) from Xerox Copying Machine in Lingayen, Pangasinan.
• Use in Court: Abalos offered these falsified documents to the RTC of Lingayen, Branch 37, as supporting documents for his Bill of Costs in Civil Case No. 15958, giving the impression they were authentic and causing damage to Evelyn C. Soriano, the adverse party.
• The Charges: Separate informations for falsification of private documents were filed: one in the MTCC of Dagupan City (Crim. Case No. 22707) covering the three Dagupan receipts, and another in the MTC of Lingayen (Crim. Case No. 10024) covering the two Lingayen invoices.

• Territorial Jurisdiction: Petitioner argued that the MTCC Dagupan and MTC Lingayen could not simultaneously exercise jurisdiction because only one crime was committed, characterized by a unified and indivisible criminal intent that became evident only when the documents were submitted in court in Lingayen.
• Forum Shopping: Petitioner contended that filing two separate complaints using the same complaint-affidavit and annexes in two different courts constitutes forum shopping.
• Duplicity of Offense: Petitioner claimed that if multiple offenses were indeed committed, the informations should be dismissed for charging more than one offense in a single information, violating Section 13, Rule 110 of the Rules of Court.

• Territorial Jurisdiction: Respondent, through the OSG, countered that both courts properly assumed jurisdiction because the falsifications involved different acts committed in different locations—some in Dagupan and others in Lingayen.
• Separate Offenses: Respondent argued that each falsified document constitutes a separate act of falsification, citing People v. Madrigal-Gonzales, and that the use of multiple falsified documents during one occasion does not diminish the number of acts of falsification committed.

• Territorial Jurisdiction: Whether the MTCC Dagupan and MTC Lingayen have territorial jurisdiction over the respective falsification charges.
• Forum Shopping: Whether filing separate complaints supported by identical affidavits and annexes in two different courts constitutes forum shopping.
• Duplicity: Whether the informations are dismissible for charging multiple offenses in a single information.

• Territorial Jurisdiction: Both courts properly acquired territorial jurisdiction. The crime of falsification of a private document is committed at the time the document is signed or falsified with the coetaneous intent to cause damage, not when the document is subsequently used. Because the cash receipts were falsified in Dagupan and the invoices in Lingayen, the respective courts where these acts occurred had jurisdiction.
• Forum Shopping: No forum shopping exists because five separate offenses of falsification were committed. There are as many acts of falsification as there are documents falsified; thus, filing separate informations in the appropriate venues was proper.
• Duplicity: While lumping multiple offenses in a single information violates Section 13, Rule 110 of the Rules of Court, the objection was waived. Petitioner failed to raise the issue of duplicity during arraignment in either Dagupan or Lingayen, raising it for the first time only in the petition before the Supreme Court. Such belated objection is unavailing.

• Territorial Jurisdiction in Criminal Cases — Jurisdiction in criminal actions is determined by the place where the offense was committed or where any of its essential ingredients took place. A court cannot validly take cognizance of offenses committed outside its territorial jurisdiction.
• Falsification of Private Documents; Time of Commission — The act of falsification is committed by the signing of the document and the coetaneous intent to cause damage. Whether the falsified private document was subsequently put to illegal use is not a material or essential element of the crime.
• Multiplicity of Falsifications — There are as many acts of falsification as there are documents falsified. The use of several falsified documents during one occasion does not diminish the number of acts of falsification committed.
• Waiver of Objection to Duplicity — An objection to a duplicitous information (one charging more than one offense) must be raised before arraignment. Failure to do so constitutes a waiver, and the objection cannot be raised for the first time on appeal.

• "The offenses of falsification took place much earlier, separately, when the cash receipts were produced repetitively in Dagupan and Lingayen."
• "There are as many acts of falsification as there are documents falsified."
• "The act of falsification is committed by the signing of the document and the coetaneous intent to cause damage and whether the falsified private document was thereafter put or not put to the illegal use for which it was intended is in no wise a material or essential element of the crime of falsification of a private document."

• Alfelor, Sr. v. Intia, 70 SCRA 480 — Cited for the principle that the place where the criminal offense was committed determines venue and is an essential element of jurisdiction for municipal courts.
• Lopez v. City Judge, 18 SCRA 616 — Followed for the rule that falsification is committed upon signing the document with coetaneous intent to cause damage, and subsequent use is not an essential element.
• People v. Madrigal-Gonzales, 7 SCRA 942 (1963) — Followed for the principle that using several falsified documents on one occasion does not diminish the number of separate acts of falsification committed.
• People v. Miana, 50 Phil. 771 (1927) — Cited as controlling precedent for the rule that failure to object to a duplicitous information before arraignment constitutes a waiver of the objection.

• Section 13, Rule 110 of the Rules of Court — Provides that a complaint or information must charge but one offense, except when existing laws prescribe a single punishment for various offenses. The provision was acknowledged to have been violated by the informations, but the objection was deemed waived due to failure to raise it before arraignment.

Bellosillo, Mendoza, and Austria-Martinez, JJ., concur. Callejo, Sr., J., no part, concurred in subject decision.