Case Digest (G.R. No. L-17994)
Facts:
The case involves Federico Batolanon and Teodoro V. Nano as petitioners and appellants against Hon. Roman A. Leorente, Justice of the Peace of Tagum, Davao, as the respondent and appellee. The events leading to this case began on September 13, 1956, when Federico Batolanon sent a letter to Attorney Irineo D. Benavides, rejecting a demand for payment of P1,000 for legal services he claimed he never hired. In the letter, Batolanon accused Benavides of committing fraud by filing false and groundless cases against individuals he claimed were innocent, specifically in Civil Case No. 1842 and Criminal Case No. 1092. He alleged that Benavides had coerced him into fabricating testimony against these individuals, despite knowing that the real cause of his injuries was an accident involving a jeep driven by another party.
On December 10, 1956, the Chief of Police, Jose V. Bosque, filed a complaint against Batolanon for light threats under Article 283 of the Revised Penal Code. The c...
Case Digest (G.R. No. L-17994)
Facts:
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.
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.
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.
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:
- Whether the facts alleged in the complaint constitute the crime of light threat under Article 283 of the Revised Penal Code.
- Whether the crime of light threat had prescribed, thereby depriving the Justice of the Peace Court of jurisdiction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)