Case Digest (G.R. No. 199930)
Facts:
Melita O. Del Rosario v. People of the Philippines, G.R. No. 199930, June 27, 2018, Supreme Court Third Division, Bersamin, J., writing for the Court. The petitioner, Melita O. Del Rosario (a former Bureau of Customs official), was charged by the State for failing to file her sworn Statement of Assets, Liabilities and Net Worth (SALN) for the years 1990 and 1991 in violation of Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees). The complaint was initiated by the Office of the Ombudsman on October 28, 2004; criminal informations were filed in the Metropolitan Trial Court (MeTC) on March 11, 2008 as Criminal Case Nos. 444354 and 444355.In the MeTC the petitioner moved to quash both informations on the ground of prescription; the MeTC granted the motion on September 18, 2009 and, after reconsideration by the State, affirmed its quashal on April 23, 2010. The State appealed to the Regional Trial Court (RTC), Branch 32, Manila, which, in a decision promulgated October 6, 2010, upheld the MeTC's orders quashing the informations.
The State elevated the RTC ruling to the Sandiganbayan, which reversed the RTC on August 16, 2011 and ordered the MeTC to proceed with trial. The Sandiganbayan applied the discovery (or blameless ignorance) rule—relying on the Behest Loans jurisprudence—and reckoned prescription from discovery rather than from the date of commission. Dissatisfied, the pe...(Subscriber-Only)
Issues:
- Did the prescriptive period for the charged violations begin to run from the date of discovery of the non-filing of the SALNs rather than from the date of commi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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