G.R. No. 199930 - Del Rosario vs. People

The petitioner, Melita O. Del Rosario, was charged with failing to file her detailed sworn Statement of Assets, Liabilities, and Net Worth (SALN) for the years 1990 and 1991, a requirement imposed by Republic Act No. 6713.
The SALN filing deadlines under R.A. No. 6713 mandate that the document be submitted “on or before April 30” of every year, establishing a clear and public accountability standard for public officials and employees.

On October 28, 2004, the General Investigation Bureau-A of the Office of the Ombudsman filed a complaint charging the petitioner with violations of Section 8 of R.A. No. 6713, along with allegations of dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service.
On March 11, 2008, the Office of the Ombudsman initiated criminal charges in the Metropolitan Trial Court (MeTC) through Criminal Cases Nos. 444354 and 444355, corresponding respectively to the alleged non-filing of the SALN for the years 1990 and 1991.
On November 19, 2008, the petitioner filed a Motion to Quash the charges on the ground that the offenses had prescribed.
The MeTC granted the Motion to Quash on September 18, 2009 and reaffirmed it on April 23, 2010 upon reconsideration.
The State appealed the quashal ruling to the Regional Trial Court (RTC), which on October 6, 2010, upheld the MeTC’s order quashing the information.
The State then elevated the case to the Sandiganbayan, which overruled the RTC decision on August 16, 2011, determining that the eight‐year prescriptive period should be reckoned from the commission of the offense, not from its discovery.
The petitioner, dissatisfied with the Sandiganbayan’s ruling, sought review and reversal of that decision.

R.A. No. 6713, enacted in 1989, sets forth the filing requirements for SALNs and embodies the latest legislative commitment to transparency and public accountability.
Though R.A. No. 6713 does not expressly provide a prescriptive period for its violations, the absence of such a provision necessitates the application of Act No. 3326, which fixes the prescriptive period at eight years for offenses punishable by imprisonment for two years or more, but less than six years.
While R.A. No. 3019 (the Anti-Graft and Corrupt Practices Act) provides a different (15-year) prescriptive period for certain violations, its prescription rules are not applicable in this instance since the charge does not allege violation of its specific filing deadlines.

The information charged against the petitioner was based on her failure to file SALNs by the published deadlines, and these SALNs, by law, are available for public inspection and copying.
The argument concerning the discovery rule (i.e., that prescription should run from the time the failure to file was discovered) was raised by the Sandiganbayan; however, the facts indicate that the omission was not concealed nor was there any indication of connivance in its non-filing.
Prior guidelines, including memorandum circulars by the Civil Service Commission and the Office of the Ombudsman, provided for monitoring compliance, hence making the violation a matter readily apparent to the government agencies tasked with oversight.

Whether the eight-year prescriptive period for the violation of R.A. No. 6713 commences from the date of commission of the offense or from the date of discovery of the offense.

Whether the application of the discovery rule, as observed in previous cases involving R.A. No. 3019 and in the so-called Behest Loans Cases, is appropriate in circumstances where the offense is inherently public and the omission could not have been easily concealed.
Whether it is proper to differentiate between the filing requirements under R.A. No. 6713 and R.A. No. 3019 in determining the prescriptive period.