G.R. No. L-37396 - Lontok, Jr. vs. Gorgonio

Marcelino Lontok, Jr. was charged in the Municipal Court of San Juan, Rizal for the crime of reckless imprudence resulting in damage to property and multiple physical injuries.
The information filed against him comprised a composite or complex charge (delito compuesto) that combined two distinct offenses arising from a single act of recklessness.

On November 14, 1972, while Lontok was recklessly driving his Mercedes Benz, he collided with a passenger jeep.
As a result of the collision:

The jeep sustained physical damage amounting to P780.
Three passengers of the jeep suffered physical injuries, rendering them unable to perform their customary labor for a period of less than ten days.

Following the filing of the information in Criminal Case No. 26116, Lontok raised a legal challenge by filing a motion to quash the portion of the charge that dealt with "lesiones leves" (slight physical injuries) through reckless imprudence.
His contention was based on the defense that the offense of slight physical injuries, as charged, prescribed in two months. Since the incident occurred on November 14, 1972, the prescription period would have ended on January 14, 1973; hence, the charge should no longer be valid.
The prosecuting fiscal opposed the motion, and the municipal court denied Lontok's motion to exclude the light offense from the information.
Instead of proceeding to trial, Lontok subsequently filed a petition in the Supreme Court on August 30, 1973, seeking an order to amend the information by removing the charge for slight physical injuries through reckless imprudence.

That damage to property through reckless imprudence should not be complexed with the light offense of slight physical injuries.
That the latter offense had already prescribed as its period of prescription had lapsed.

Despite his concurrence with the substance of the issue, the Solicitor General argued that because Lontok did not raise any jurisdictional impediment, his petition for certiorari was not proper and should therefore be dismissed.

Whether Lontok, despite his objection, can be tried in the Municipal Court on a single information that charges him with a complex crime combining:

Damage to property through reckless imprudence (a less grave felony).
Slight physical injuries through reckless imprudence (a light offense that already prescribed).

Whether the combination of a less grave felony with a light offense in a single information constitutes a valid complex crime under the Revised Penal Code.
Whether the prescription of the light offense should preclude its inclusion in a composite charge with a separate and independently punishable act.