Manduriao v. Habana
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from an incident on February 21, 1962, where Paula Manduriao allegedly uttered defamatory words against Gloria Serrano and then physically assaulted her, boxing her on the face and forehead, causing injuries expected to heal within ten days. This led to a complaint filed by the acting chief of police of Bacon, Sorsogon. 2. Procedural History: Initially, a complaint for grave slander with slight physical injuries was filed in the justice of the peace court. Paula Manduriao waived preliminary investigation, and the case moved to the Court of First Instance. The fiscal moved to dismiss the slander charge, recognizing it as improper, and requested the case be remanded for prosecution of lesiones leves only. The Court of First Instance granted this, and an amended complaint for lesiones leves was filed in the inferior court. Manduriao's motion to quash was denied, leading her to file a petition for prohibition in the Court of First Instance, arguing prescription. This petition was dismissed, and the case was elevated to the Court of Appeals, which then forwarded it to the Supreme Court due to the question of law involved. 3. The Petition: Paula Manduriao appealed the dismissal of her prohibition petition, contending that the offense of lesiones leves had prescribed. She argued that the amended complaint was invalid because the original case had been dismissed and that the prescriptive period for light offenses (two months) had elapsed. She relied on Article 90 of the Revised Penal Code. The Supreme Court, however, affirmed the lower court's decision, holding that the filing of the original complaint interrupted the prescriptive period as per Article 91 of the Revised Penal Code, and the subsequent proceedings did not cause the interruption to cease.
Issue(s)
Whether the offense of lesiones leves had prescribed. Whether the amended complaint was valid and retroacted to the filing of the original complaint.
Ruling
The petition is dismissed. The order of the lower court dismissing the petition for prohibition is affirmed. The municipal court of Bacon is directed to try Criminal Case No. 812. Costs against the petitioner-appellant.
Ratio Decidendi
On whether the offense of lesiones leves had prescribed: The Court held that the offense had not prescribed. Article 91 of the Revised Penal Code provides that the period of prescription is interrupted by the filing of a complaint or information and commences to run again when such proceedings terminate without conviction or acquittal, or are unjustifiably stopped. In this case, the sixty-day prescriptive period for light offenses was interrupted on February 24, 1962, when the original complaint was filed. Only three days of the prescriptive period had elapsed at that point. The interruption continued throughout the proceedings, including the amendment of the complaint, which was done to implement the CFI's order to proceed with the lesiones leves charge. The Court found the argument that the amended complaint was invalid because the original case was dismissed to be captious, as the dismissal of the grave slander charge was without prejudice, and the case for slight physical injuries was remanded for trial on the merits. Therefore, the amended complaint was considered valid and retroacted to the filing of the original complaint. On whether the amended complaint was valid and retroacted to the filing of the original complaint: The Court affirmed the lower court's ruling that the amended complaint was valid and retroacted to the filing of the original complaint. The fiscal's motion to dismiss the grave slander charge was made because it was improperly joined with lesiones leves and required a different mode of prosecution. The CFI's order to dismiss the grave slander charge without prejudice and to remand the case for the prosecution of lesiones leves was clear. The chief of police merely amended the complaint to conform to this order, eliminating the grave slander charge and proceeding solely with the lesiones leves charge. This action did not terminate the proceedings for lesiones leves but rather continued them. Thus, the amended complaint was a continuation of the original action, and its filing was deemed to have interrupted the prescriptive period from February 24, 1962.
Main Doctrine
The filing of an original complaint or information interrupts the period of prescription of a crime, and the prescriptive period commences to run again only when such proceedings terminate without the accused being convicted or acquitted, or are unjustifiably stopped for any reason not imputable to him. An amended complaint filed pursuant to a court order, which merely implements the dismissal of a previous charge without prejudice and remands the case for trial on the merits for the remaining offense, is considered to have retroacted to the filing of the original complaint for purposes of prescription.