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People vs. Matan

The case involves Guillermo Manantan appealing a court ruling that remanded his case for trial after an initial dismissal, claiming double jeopardy. The court ruled that Manantan waived his right to this defense by not raising it during the appeal process, leading to the denial of his motion for reconsideration. The ruling emphasizes the necessity of timely raising the defense of double jeopardy to be considered valid.

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10 views2 pages

People vs. Matan

The case involves Guillermo Manantan appealing a court ruling that remanded his case for trial after an initial dismissal, claiming double jeopardy. The court ruled that Manantan waived his right to this defense by not raising it during the appeal process, leading to the denial of his motion for reconsideration. The ruling emphasizes the necessity of timely raising the defense of double jeopardy to be considered valid.

Uploaded by

tibok.13
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd

Case Digest (G.R. No.

L-14129)
Comprehensive

Facts:

• The case involves the People of the Philippines as the plaintiff-appellant and Guillermo
Manantan as the defendant-appellee.

• The resolution was issued on August 30, 1962, by Justice Regala.

• Guillermo Manantan filed a motion for reconsideration against the court's ruling,
which had remanded his case to the lower court for trial on the merits.

• Initially, the lower court had dismissed the charge against Manantan.

• Manantan argued that this dismissal placed him in jeopardy, invoking the principle of
double jeopardy.

• He cited the case of People vs. Labatete to support his claim that jeopardy had already
attached when the lower court dismissed the charge.

• The court noted that Manantan had multiple opportunities to raise the defense of
double jeopardy during the appeal process but failed to do so, thereby waiving his
constitutional right.

• The Solicitor General represented the plaintiff-appellant, while the Padilla Law Office
represented the defendant-appellee.

Issue:

• Does remanding the case to the lower court for trial on the merits place the defendant-
appellee, Guillermo Manantan, in double jeopardy?

• Did the defendant-appellee waive his constitutional right against double jeopardy by
failing to raise it during the appeal process?

Ruling:

• The court ruled that the plea of double jeopardy should be rejected.

• The court denied the motion for reconsideration filed by the defendant-appellee,
Guillermo Manantan.

Ratio:

• The court's decision was based on the principle that the defense of double jeopardy
must be timely raised to be considered.

• Manantan had multiple opportunities to invoke this defense during the appeal process
but failed to do so.

• Specifically, he could have resisted the state's appeal or argued the double jeopardy
issue in his appeal brief.

• By not raising the defense at these critical junctures, Manantan effectively waived his
constitutional right against double jeopardy.

• The court cited previous rulings, such as People vs. Rosalina Casiano and People vs.
Pinuila, to support the notion that failure to raise the defense in a timely manner
constitutes a waiver.
• The court also noted that other grounds raised by the defendant-appellee in his motion
for reconsideration were not well-founded.

• Therefore, the motion for reconsideration was denied, and the case was remanded for
trial on the merits.

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