Corpus v. People
REITERATIONFacts
The Antecedents: The underlying dispute arose from an alleged physical altercation on November 25, 2017, where Roberto Amado Hatamosa accused Pastor Corpus, Jr., Resurecion Zamora, and Felix Corpus of intercepting him, verbally confronting him, and then assaulting him. Pastor allegedly punched Roberto in the face, and the other two accused joined in, resulting in physical injuries to Roberto, including a fractured right hand finger. Procedural History: Initially, a complaint for slight physical injuries was filed. However, the Senior Assistant City Prosecutor recommended indictment for serious physical injuries due to the fracture, which was considered a disfigurement. An Information for serious physical injuries was filed on May 21, 2018. Pastor pleaded not guilty. The Metropolitan Trial Court (MeTC) acquitted Zamora and Felix but found Pastor guilty of slight physical injuries, sentencing him to 30 days of arresto menor and ordering him to pay moral damages. The Regional Trial Court (RTC) affirmed this decision. The Court of Appeals (CA) also affirmed the conviction, ruling that the Information for serious physical injuries had not prescribed and that Pastor could be convicted of the lesser offense of slight physical injuries. The Petition: Pastor Corpus, Jr. filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. He argued that the crime of slight physical injuries, for which he was convicted, had already prescribed. He also raised the issue of self-defense. The Supreme Court granted the petition, finding merit in the argument that the conviction for slight physical injuries was erroneous because the crime had prescribed by the time the Information was filed, despite the charge being for the graver offense of serious physical injuries.
Issue(s)
Whether the factual issues raised by Pastor Corpus, Jr. y Belmoro are beyond the ambit of a Petition for Review on Certiorari Under Rule 45 of The Rules of Court. Whether the CA correctly ruled that the information charging Pastor Corpus, Jr. y Belmoro for serious physical injuries had not prescribed. Whether the CA correctly affirmed Pastor Corpus, Jr. y Belmoro's conviction for the crime of slight physical injuries.
Ruling
The Petition is GRANTED. The Decision and Resolution of the Court of Appeals are REVERSED. Pastor Corpus, Jr. y Belmoro is ACQUITTED of the crime of Slight Physical Injuries on the ground of prescription.
Ratio Decidendi
On the issue of factual issues being beyond the ambit of Rule 45: While generally factual issues are not reviewed in a Rule 45 petition, the Supreme Court may delve into them when, as in this case, the lower courts' findings are not supported by the evidence or when there is a misapprehension of facts. The core issue here revolved around the prescription of the offense, which is a question of law arising from the established facts. On whether the CA correctly ruled that the information charging Pastor Corpus, Jr. y Belmoro for serious physical injuries had not prescribed: The Information was filed on May 21, 2018, for an incident on November 25, 2017. Serious physical injuries, punishable by prisión correccional, prescribes in ten (10) years. Therefore, the crime of serious physical injuries, as charged in the Information, had not prescribed at the time the Information was filed. On whether the CA correctly affirmed Pastor Corpus, Jr. y Belmoro's conviction for the crime of slight physical injuries: The Supreme Court found that while the variance doctrine allowed conviction for a lesser included offense, the criminal liability for slight physical injuries had been extinguished by prescription. Slight physical injuries is a light offense, which prescribes in two (2) months. The incident occurred on November 25, 2017. The Complaint-Affidavit was executed on January 8, 2018, but the Information was filed only on May 21, 2018. For crimes governed by the Rules on Summary Procedure in Metropolitan Manila, the prescriptive period is tolled only by the filing of the Information in court. The period from November 25, 2017, to May 21, 2018, is 177 days, which exceeds the two-month prescriptive period. Therefore, Pastor's criminal liability for slight physical injuries had already prescribed when the Information was filed.
Main Doctrine
The crime of slight physical injuries, being a light offense governed by the Rules on Summary Procedure, prescribes in two months. In Metropolitan Manila and Chartered Cities, the prescriptive period is tolled only by the filing of an Information in court, not by the commencement of a preliminary investigation or the filing of a complaint with the prosecutor's office. Consequently, if the Information for slight physical injuries is filed beyond the two-month prescriptive period, the criminal liability is extinguished by prescription, even if the accused was charged with a graver offense that has not yet prescribed.