Title
IN RE: Astero vs. Chief of Police of Dagupan City
Case
G.R. No. L-26741
Decision Date
Jul 31, 1969
The Supreme Court recognizes the authority of any competent person to lay a complaint for a public crime and clarifies the power of the City Court of Dagupan to conduct preliminary investigations, ruling that a complaint for a public crime can be filed by any competent person and the arrest and confinement based on such a complaint are lawful and valid.
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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:

  • (Unlock)

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

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