Title
Batolanon vs. Leorente
Case
G.R. No. L-17994
Decision Date
Aug 31, 1963
Batolanon accused Benavides of fabricating cases, leading to a criminal complaint for light threat; Supreme Court upheld jurisdiction, affirming the charge and its timeliness.
Font Size:

Case Digest (G.R. No. L-17994)

Facts:

  1. Background of the Case:

    • Federico Batolanon wrote a letter to Attorney Irineo D. Benavides on September 13, 1956, accusing him of fabricating cases and demanding P1,000 as damages for the alleged fraud committed against him.
    • Batolanon claimed that Benavides knowingly prosecuted false cases against Langga Sanama and others, despite knowing that the injuries Batolanon sustained were caused by a jeep accident, not by Sanama and his companions.
  2. Criminal Complaint:

    • On December 10, 1956, the Chief of Police filed a complaint in the Justice of the Peace Court of Tagum, Davao, charging Batolanon with the crime of light threat under Article 283 of the Revised Penal Code.
    • The complaint was later amended to include Attorney Teodoro V. Nano as a co-defendant, based on the belief that Nano authored the letter.
  3. Procedural History:

    • The defendants filed a motion to quash the complaint, which was denied. They subsequently filed motions for reconsideration, arguing that the crime had prescribed and that the facts did not constitute an offense.
    • The Justice of the Peace Court denied all motions, and the case proceeded.
    • The defendants then filed a petition for certiorari and prohibition in the Court of First Instance of Davao, seeking to restrain the Justice of the Peace Court from hearing the case.
    • The Court of First Instance ruled that the crime had not prescribed and that the Justice of the Peace Court had jurisdiction.
  4. Appeal:

    • The defendants appealed the decision, raising two main issues: whether the facts constituted the crime of light threat and whether the crime had prescribed.

Issue:

  1. Whether the facts alleged in the complaint constitute the crime of light threat under Article 283 of the Revised Penal Code.
  2. Whether the crime of light threat had prescribed, thereby depriving the Justice of the Peace Court of jurisdiction.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.