People v. Bautista
REITERATIONFacts
The Antecedents: On June 12, 1999, a dispute occurred between respondent Clemente Bautista and his co-accused, and private complainant Felipe Goyena, Jr. The private complainant filed a complaint with the Barangay of Malate, Manila, but no settlement was reached, leading to a Certification to file action dated August 11, 1999. Procedural History: On August 16, 1999, the private complainant filed a Complaint for slight physical injuries with the Office of the City Prosecutor (OCP). A Joint Resolution dated November 8, 1999, recommended the filing of an Information, which was approved by the City Prosecutor. However, the Information was filed with the Metropolitan Trial Court (MeTC) of Manila, Branch 28, only on June 20, 2000. The respondent moved for dismissal, arguing prescription. The MeTC and the Regional Trial Court (RTC) denied this, ruling the offense had not prescribed. The Court of Appeals (CA), however, reversed these rulings, holding that while the filing with the OCP interrupted prescription, the offense had prescribed by the time the Information was filed with the MeTC, citing the undue delay in filing. The Petition: The People of the Philippines filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA's decision to dismiss the criminal case.
Issue(s)
Whether the prescriptive period for the offense of slight physical injuries began to run anew after the investigating prosecutor's recommendation to file an information was approved by the City Prosecutor. Whether the offense of slight physical injuries had prescribed by the time the Information was filed with the Metropolitan Trial Court.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision of the Court of Appeals, and reinstated the decision of the Regional Trial Court. The criminal case was not dismissed on the ground of prescription.
Ratio Decidendi
On whether the prescriptive period began to run anew after the investigating prosecutor's recommendation was approved: The Court held in the negative. It reiterated the well-settled rule that the filing of a complaint with the prosecutor's office suspends the running of the prescriptive period. The proceedings against the respondent were not terminated upon the City Prosecutor's approval of the recommendation to file an information. Therefore, the prescriptive period remained tolled from the time the complaint was filed with the Office of the Prosecutor until the respondent is either convicted or acquitted by the proper court. The Court emphasized that it is unjust to deprive the injured party of the right to obtain vindication due to delays not under their control, citing People v. Olarte. The Court further clarified that the constitutional right to speedy trial is not invoked here as the delay occurred in the filing of the Information, not in the preliminary investigation or trial. On whether the offense had prescribed by the time the Information was filed: The Court found that the CA erred in concluding that the offense had prescribed. While acknowledging the delay by the Office of the Prosecutor in filing the Information, the Court ruled that such delay should not unduly prejudice the interests of the State and the offended party. The Court stated that the prescriptive period remains suspended until the termination of the case by conviction or acquittal. The CA's reasoning that the proceedings were "unjustifiably stopped" was found to be misapplied, as the tolling period continues until the case is resolved in court, not merely upon the approval of the prosecutor's recommendation. The Court stressed that it would not be made an unwitting tool in depriving the offended party of vindication due to prosecutorial inaction.
Main Doctrine
The filing of a complaint with the prosecutor's office interrupts the prescriptive period for filing a criminal action. This period remains tolled until the accused is convicted or acquitted, or the proceedings are unjustifiably stopped for reasons not attributable to the accused. Delays by the prosecution in filing the information after approval of the recommendation to file do not cause the prescriptive period to run anew and should not prejudice the State or the offended party.