Case Digest (G.R. No. 169588) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jadewell Parking Systems Corporation v. Hon. Judge Nelson F. Lidua Sr., G.R. No. 169588, decided on October 7, 2013, the petitioner, Jadewell Parking Systems Corporation represented by its manager and authorized representative Norma Tan, is a private operator empowered under Baguio City Ordinance No. 003-2000 to immobilize illegally parked vehicles by wheel‐clamping. On May 7 and May 17, 2003, respondents Benedicto Balajadia, Edwin Ang, Jeffrey Walan (and several John and Peter Does) forcibly removed clamps placed on their vehicles and carried them away, allegedly causing damage worth ₱26,250 and failing to pay prescribed fines and declamping fees. Jadewell filed two Affidavit‐Complaints with the City Prosecutor on May 23, 2003, prompting a preliminary investigation that found no probable cause for robbery but did support charges for violation of Section 21 of the city ordinance. Two Informations were subsequently filed in the Municipal Trial Court (MTC), Branch 3, Baguio Cit Case Digest (G.R. No. 169588) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Petitioner Jadewell Parking Systems Corp. is authorized under Baguio City Ordinance No. 003-2000 to operate parking spaces, clamp illegally parked vehicles (clamp cost ₱26,250; declamping fee ₱500; illegal parking fine ₱500).
- On May 17, 2003, respondents Edwin Ang, Benedicto Balajadia and John Doe forcibly removed the clamp from a Mitsubishi Adventure (Plate WRK 624), allegedly illegally parked in a loading/unloading zone; clamp not paid for or returned.
- On May 7, 2003, respondents Balajadia, Jeffrey Walan and two John Does dismantled the clamp from a Nissan Cefiro (Plate UTD 933), also illegally parked; clamp valued ₱26,250; fees unpaid.
- Procedural history
- May 23, 2003: Jadewell filed two affidavit-complaints with the City Prosecutor for robbery; preliminary investigation on May 28, 2003.
- Balajadia filed a counter-case for usurpation of authority, denied illegal parking, admitted removal as self-help and kept clamp as evidence.
- July 25, 2003: Provincial Prosecutor found no robbery but probable cause under Sec. 21 of Ordinance 003-2000; filed two informations on October 2, 2003 before MTC Baguio (Crim. Cases 112934 & 112935).
- Feb 10, 2004: MTC Branch 3 granted respondents’ motion to quash for prescription, failure to state offense, and multiplicitous charging; motion for reconsideration denied on April 16, 2004.
- RTC Branch 7 denied petitioner’s Rule 65 certiorari on April 20, 2005; motion for reconsideration denied August 15, 2005.
- Supreme Court petition
- Petitioner sought review under Rule 45, challenging dismissal based on prescription.
- Central dispute whether prescription tolled by affidavit-complaints with prosecutor or only by filing informations in court under the Rules on Summary Procedure and Act No. 3326.
Issues:
- Whether filing the affidavit-complaints with the City Prosecutor on May 23, 2003 interrupted the two-month prescription under Act No. 3326 for violation of a city ordinance.
- Whether, under the 1991 Revised Rules on Summary Procedure, violations of city ordinances in chartered cities are commenced only by information in court, thus prescription is tolled only by such filing.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)