Lontok v. Gorgonio
REITERATIONFacts
The Antecedents: On November 14, 1972, petitioner Marcelino Lontok, Jr. was allegedly driving his Mercedes Benz car recklessly, bumping a passenger jeep and causing damage to property amounting to P780. The incident also resulted in physical injuries to three passengers, incapacitating them from performing their customary labor for less than ten days. Procedural History: On March 29, 1973, an information was filed charging Lontok, Jr. with the complex crime of reckless imprudence resulting in damage to property and multiple physical injuries (lesiones leves). Lontok, Jr. filed a motion to quash the part of the information pertaining to the offense of lesiones leves through reckless imprudence, contending that this light offense had already prescribed as it prescribes in two months, with the period expiring on January 14, 1973. The fiscal opposed the motion, which was denied by the municipal court. Lontok, Jr. pleaded not guilty upon arraignment. The Petition: Instead of proceeding to trial, Lontok, Jr. filed a petition for certiorari with the Supreme Court, praying for an order to amend the information by deleting the charge of slight physical injuries through reckless imprudence.
Issue(s)
Whether the charge of reckless imprudence resulting in damage to property and multiple physical injuries (lesiones leves) constitutes a complex crime. Whether the offense of lesiones leves through reckless imprudence had prescribed at the time the information was filed. Whether the municipal court committed a grave abuse of discretion in denying the motion to quash.
Ruling
The Supreme Court ruled that the municipal court committed a grave abuse of discretion in denying the motion to quash. The Court ordered that Lontok, Jr. be tried only for damage to property through reckless imprudence, and that the information need not be amended, it being understood that Lontok, Jr. has no more culpability for the offense of slight physical injuries through reckless imprudence charged therein.
Ratio Decidendi
On whether the charge constitutes a complex crime: The Court held that a complex crime, as defined under Article 48 of the Revised Penal Code, requires that a single act constitute two or more grave or less grave felonies, or that a grave or less grave offense be a means of committing another grave or less grave offense. Commonwealth Act No. 4000 amended Article 48 to substitute "grave or less grave felonies" for "crimes," thereby eliminating light felonies as components of a complex crime. In this case, the offense of damage to property through reckless imprudence is a less grave felony, while lesiones leves (slight physical injuries) is a light offense. Therefore, they cannot be complexed into a single crime. The offenses should be treated as separate offenses, subject to distinct penalties. On whether the offense of lesiones leves had prescribed: The Court affirmed Lontok, Jr.'s contention that the offense of lesiones leves through reckless imprudence had prescribed. As a light offense, it prescribes in two months. Since the offense was committed on November 14, 1972, the sixty-day period for filing the charge expired on January 14, 1973. The information was filed on March 29, 1973, which was beyond the prescriptive period. Consequently, Lontok, Jr.'s criminal liability for this offense was extinguished. On whether the municipal court committed a grave abuse of discretion: The Court found that the municipal court committed a grave abuse of discretion in denying Lontok, Jr.'s motion to quash. The court should have sustained the motion because the charge of lesiones leves had prescribed and, in any event, could not be complexed with the offense of damage to property. The proper procedure would have been to file separate informations for each offense, and since the light offense had prescribed, it should have been excluded from the information.
Main Doctrine
A complex crime cannot be constituted by a single act which results in a less grave felony and a light felony. The light felony should be treated as a separate offense, and if it has already prescribed, the charge for that offense must be quashed.