Facts:

The case is Herminio A. Astorga v. The Honorable Ricardo C. Puno and Alfredo R. Gomez, with G.R. No. L-25600, decided on September 30, 1975. Petitioner Herminio A. Astorga is challenging the Orders of Respondent Judge Ricardo C. Puno of the Court of First Instance in Manila, which denied his motions for dismissal and suspension of a criminal case against him. This legal dispute stems from a complaint filed on November 2, 1965, by Alfredo R. Gomez, accusing Astorga and others of grave coercion and grave threats in violation of the Revised Election Code. These allegations arose from the local elections held on November 12, 1963, where Astorga had won the vice-mayorship against Gomez. Prior to the criminal complaint, Gomez had filed an election protest against Astorga, concerning the same acts that underpinned the criminal charges. Astorga contended that the criminal offenses had already prescribed because more than two years had passed since the alleged commission of the offenses

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Facts:

Background and Initiation of Proceedings

• On November 2, 1965, respondent Alfredo R. Gomez filed a criminal complaint against petitioner Herminio A. Astorga before the Court of First Instance of Manila.
• The complaint charged Astorga with grave coercion and grave threats in violation of the Revised Election Code, relating to events around the November 12, 1963 local elections in Manila.
• Concurrently, an election protest was filed by Gomez against Astorga, alleging fraud and terrorism that purportedly affected Astorga’s winning as Vice-Mayor.

Pre-Trial Motions and Denials

• On November 15, 1965, petitioner Astorga filed a Motion to Dismiss the criminal complaint. He argued, among other grounds, that:
• The alleged offenses had already prescribed, as the two-year period from November 12, 1963 had elapsed.
• There was a jurisdictional issue, contending that the investigation of election offenses should be conducted exclusively by the City Fiscal of Manila pursuant to the City Charter.
• The Court of First Instance, led by Judge Ricardo C. Puno (Branch XXIV), denied the motion. The Court held that the filing of the complaint had the effect of interrupting the statutory prescriptive period stipulated in Section 188 of the Revised Election Code.

Motion for Reconsideration and Subsequent Developments

• Following the denial, petitioner Astorga filed a Motion for Reconsideration on December 22, 1965. In this motion, he reiterated and expanded his arguments:
• Asserting that the offenses had already prescribed.
• Claiming that, even if there was no prescription issue, the pending election protest raised a pre-judicial question that warranted the suspension of the criminal proceedings.
• Challenging the jurisdiction of the Court of First Instance, arguing that investigating election offenses was a function reserved for the City Fiscal of Manila under Section 38 of the City Charter.
• The Motion for Reconsideration was likewise denied by the respondent Court.

Further Developments and Relief Sought by Petitioner

• An Order reset the preliminary investigation for February 2, 1966.
• Believing that the respondent Court had acted with grave abuse of discretion and had exceeded its jurisdiction, petitioner filed a petition for certiorari and prohibition.
• Concurrently, a Temporary Restraining Order was issued on February 2, 1966, directing Judge Puno to refrain from proceeding with the preliminary investigation of Criminal Case No. 80557.
• Petitioner’s main contentions included:
• The Court of First Instance lacked jurisdiction to conduct the preliminary investigation because election offense investigations should be exclusively conducted by the City Fiscal.
• The criminal trial should be suspended due to an existing pre-judicial question raised in the pending election protest (Civil Case No. 55820).
• The offenses charged had already prescribed since the alleged commission of the crimes occurred more than two years before the filing of the complaint.

Respondents’ Position

• Respondents maintained that Section 187 of the Revised Election Code explicitly vests the Court of First Instance with exclusive jurisdiction to conduct preliminary investigations into election offenses.
• They argued that the filing of the complaint within the prescribed period does indeed halt the running of the prescriptive period as provided by Section 188 of the Election Code.
• They further asserted that the pending election protest was directed at contesting election results and did not preclude the criminal investigation concerning the alleged misconduct in the precincts.

Issue:

Jurisdiction Issue

• Whether the Court of First Instance had the jurisdiction to conduct the preliminary investigation of the criminal complaint, given petitioner’s contention that the City Fiscal of Manila should exclusively handle election offense investigations pursuant to the City Charter.

Prescription Issue

• Whether the filing of the criminal complaint with the Court of First Instance effectively interrupted the two-year prescriptive period under Section 188 of the Revised Election Code despite the passage of time since the alleged offenses.

Pre-Judicial Question Issue

• Whether the pending election protest, which raised issues of fraud and terrorism, constituted a valid pre-judicial question necessitating the suspension of the criminal proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)