Case Digest (G.R. No. L-26741)
Facts:
- Leticia del Pilar, a minor, filed a complaint with the City Court of Dagupan on August 18, 1966, charging Lita Mendoza, Susan Dequito, Susana Soriano, and Tessie Astero with corruption of a minor.
- The complaint alleged that the accused promoted or facilitated the prostitution or corruption of Leticia del Pilar through force, threats, and intimidation.
- After conducting a preliminary examination, the City Court issued a warrant of arrest, and Tessie Astero was apprehended and confined in the City Jail of Dagupan.
- On October 7, 1966, Astero filed a petition for habeas corpus in the Court of First Instance of Pangasinan, arguing that the complaint against her was null and void because only the City Fiscal had the authority to institute criminal actions and because the crime of corruption of a minor is a purely public crime.
Issue:
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Ruling:
- A complaint for a public crime can be laid by any competent person, as explicitly provided in Section 1 of Rule 110 of the Rules of Court.
- The City Court of Dagupan has the authority to conduct preliminary investigations, as granted by the City Charter.
- Therefore, a complaint filed by a person oth...(Unlock)
Ratio:
- Section 1 of Rule 110 of the Rules of Court explicitly provides that any competent person can lay a complaint for a public crime.
- The City Charter of Dagupan grants the city court the authority to conduct preliminary investigations, which implies that the City Attorney shares that function with the court.
- The different provisions of the law should be construed to harmonize them, and the last provision in point of time or order of arrangement prev...continue reading
Case Digest (G.R. No. L-26741)
Facts:
The case of In re: Astero v. Chief of Police of Dagupan City involves a petition for habeas corpus filed by Tessie Astero against the Chief of Police of Dagupan City. The petitioner, Tessie Astero, was charged with "corruption of a minor" based on a complaint filed by Leticia del Pilar, a minor who accused Astero and others of promoting her prostitution. After conducting a preliminary examination, the City Court of Dagupan issued a warrant of arrest, leading to the petitioner's apprehension and confinement in the City Jail of Dagupan. The petitioner then filed a petition for habeas corpus, arguing that the complaint filed by del Pilar was null and void because only the City Fiscal had the authority to institute criminal actions and that there was no civil liability involved in the case. The Court of First Instance of Pangasinan granted the petition and ordered the release of the petitioner.
Issue:
The main issue in the case is whether the complaint filed by a private individual for a public crime is valid and whether the City Court of Dagupan has the authority to conduct preliminary investigations.
Ruling:
The Supreme Court ruled that the complaint filed by a private individual for a public crime is valid. The Court cited Section 1 of Rule 110 of the Rules of Court, which explicitly provides that all criminal actions must be commenced either by complaint or information...