People v. Yu
REITERATIONFacts
The Antecedents: On October 22, 1954, Yu Hai alias "Haya" was accused in the Justice of the Peace Court of Caloocan for violating Article 195, sub-paragraph 2 of the Revised Penal Code. The charge alleged that he permitted and maintained the game of panchong or paikiu, a game of hazard, in Caloocan on or about June 26, 1954. Procedural History: The accused moved to quash the information, arguing it charged multiple offenses and that the criminal action had already been extinguished. The Justice of the Peace Court sustained the motion, ruling that the offense was a light offense and had prescribed in two months under Article 90 of the Revised Penal Code. The provincial fiscal appealed to the Court of First Instance, which affirmed the dismissal. The fiscal then appealed directly to the Supreme Court. The Petition: The sole issue presented to the Supreme Court was the correct prescriptive period for the offense charged.
Issue(s)
Whether the offense charged, punishable by arresto menor or a fine not exceeding ₱200.00, is a light offense that prescribes in two months or a less grave felony that prescribes in ten years.
Ruling
The Supreme Court affirmed the decision of the lower court, ruling that the offense charged has prescribed. The Court held that the offense is a light offense and prescribes in two months.
Ratio Decidendi
On Issue 1: The Supreme Court held that the offense is a light felony that prescribes in two months. The Court reasoned that Article 90 provides that "light offenses prescribe in two months" but does not define the term, thus necessitating a reference to Article 9, which defines light felonies as infractions punishable by arresto mayor or a fine not exceeding ₱200.00. While the Solicitor General pointed to Article 26, which classifies a ₱200.00 fine as a correctional penalty, the Court clarified that Article 26 deals with the classification of the penalty itself, whereas Article 9 deals with the classification of the offense for purposes of prescription. The Court emphasized that adopting the Solicitor General's theory would lead to the absurd result where a one-peso difference in a fine could extend the prescriptive period by nearly ten years. Furthermore, applying the SG's theory would mean that more serious offenses punishable by arresto mayor (a correctional penalty) would prescribe in five years, while a lighter offense with a ₱200.00 fine would take ten years to prescribe. Finally, the Court invoked the principle that criminal statutes must be strictly construed against the government and liberally in favor of the accused; thus, the shorter prescriptive period under Article 9 must be applied. Since the alleged crime occurred on June 26, 1954, and the information was filed only on October 22, 1954, the two-month period had clearly lapsed.
Main Doctrine
An offense punishable by arresto menor or a fine not exceeding P200, or both, is classified as a light offense under Article 9 of the Revised Penal Code, and therefore prescribes in two months as provided by Article 90 of the same Code. The classification of the fine as correctional under Article 26 does not alter the prescriptive period for light offenses.