Since Chi-Ha is being put forward as tier 3, I will compare it to the T82's derp gun. I will use the stats provided by OP on the Naval Short 12cm gun. Since Wikipedia states that it was a "short barrel" gun and this gun has "short" in it's name and also because it was a Navy version of the Chi-Ha so I'm just assuming it's the same gun.
The Naval Short 12-cm Gun had a barrel length L/12 (1440mm), whereas the M3 Howitzer had a length L/16 (1680mm).
The 12cm HE round had a muzzle velocity of 290m/s, whereas the M3 Howitzer HE round had a muzzle velocity of 311 m/s.
The 12cm HE round had a shell weight 11800g and 2500g filling, whereas the M3 Howitzer HE round had a shell weight of 18350g and 2180g filling.
Lower shell weight, slower muzzle velocity, and shorter gun barrel tells me that an in-game Naval Short 12cm gun would have less penetration values, worse accuracy, and less range than the 105 mm AT Howitzer M3. However, the bigger filling of the 12cm shell than the M3 shell tells me that it would have slightly more damage. The Naval Short 12cm gun is clearly not the same as the high tier 120mm guns, in fact, in some respects would be worse than the M3 Howitzer used by the T82.
However, its 400+ damage cannot be ignored. Even if it had 1mm penetration, it would do guaranteed 50% dmg so long as the HE shell blew up on the armor.










