People v. Crisostomo
REITERATIONFacts
The Antecedents: On October 26, 1954, Ng Guat, et al. were charged with violating Article 195(a) of the Revised Penal Code for operating slot machines on July 19, 1954. Similarly, on November 15, 1954, Rufino Crisostomo, et al. were charged with the same offense. Procedural History: The Justice of the Peace Courts of Caloocan and Navotas dismissed the charges on the ground of prescription, except for George Philips, whose case was reinstated as he was outside the country when the offense was discovered and the information filed. The Provincial Fiscal appealed to the Court of First Instance of Rizal, which affirmed the dismissal orders. The prosecution then appealed to the Supreme Court. The Petition: The prosecution appealed the dismissal orders, raising the sole issue of whether the offenses, punishable by arresto menor or a fine not exceeding 200 pesos, prescribe in two months as held by the trial court, or in ten years as contended by the State.
Issue(s)
Whether offenses punishable by arresto menor or a fine not exceeding 200 pesos prescribe in two months. Whether the offenses charged had prescribed.
Ruling
The Supreme Court affirmed the orders of dismissal, holding that offenses punishable by arresto menor or a fine not exceeding 200 pesos are light offenses that prescribe in two months, as per Article 90, paragraph 6 of the Revised Penal Code. The Court reiterated its previous rulings on this matter and found no error in the trial court's dismissal of the charges due to prescription.
Ratio Decidendi
On the prescription of offenses: The Court reiterated its established doctrine that offenses punishable by arresto menor or a fine not exceeding 200 pesos are classified as light offenses under Article 9 of the Revised Penal Code. Consequently, these offenses prescribe in two months, as provided by Article 90, paragraph 6 of the same Code. This ruling aligns with previous decisions of the Court in People vs. Yu hai, People vs. Aquino, and People vs. Canson. The Court found no reason to abandon this established jurisprudence. Therefore, the trial court correctly applied the law in dismissing the charges on the ground of prescription, as the prescriptive period had already elapsed. On the application of the prescription period to the charged offenses: Given the classification of the offenses as light offenses, the prescriptive period applicable is indeed two months. The Court noted that the informations were filed beyond this period. The fact that the offenses involved violations of the gambling law did not alter the prescriptive period as defined by the Revised Penal Code. The Court acknowledged a potential conflict or discrepancy between Articles 9 and 26 of the Revised Penal Code regarding the classification of offenses and their prescriptive periods, particularly concerning gambling offenses. However, based on the existing provisions and established jurisprudence, the two-month prescriptive period for light offenses was correctly applied by the lower courts. The Court suggested that the Legislature might consider resolving this conflict through suitable legislation or amendment.
Main Doctrine
Offenses punishable by arresto menor or a fine not exceeding 200 pesos are considered light offenses and prescribe in two months under Article 90, paragraph 6 of the Revised Penal Code.