G.R. No. 137162 - Escueta vs. Lim

A criminal complaint for "crave threats" was lodged by Leonardo Argente against petitioner-appellant Bienvenido Medrano.
The alleged act took place on September 30, 1963, and the complaint was filed on November 29, 1963, in the Municipal Court of Ibaan, Batangas.

At Medrano’s instance, the municipal court reconsidered its initial decision.
On March 14, 1964, the court directed the private prosecutor to amend the complaint within five (5) days from receipt of the order, narrowing the charge to "light threats" only.
The private prosecutor received the order on March 18, 1964.

The amended complaint, now charging only light threats, was filed on April 15, 1964, which was 28 days after the order was received.
This delay in filing exceeded the prescribed five-day period set by the municipal court.

On April 23, 1964, Medrano filed a written motion to quash the amended complaint on the ground of prescription.
This motion reiterated an earlier oral motion made on April 16, 1964.
The municipal court again denied his motion to quash, prompting Medrano to elevate the issue.

Medrano filed a petition for prohibition before the Court of First Instance of Batangas, alleging that the municipal court’s refusal to quash the case was a grave abuse of discretion and a direct violation of Article 91 of the Revised Penal Code.
The People of the Philippines were duly required to answer the petition.
On November 2, 1964, the Court of First Instance rendered a decision dismissing the petition, and Medrano’s motion for reconsideration was also denied.

The sole legal issue now presented on appeal was whether the prescription had set in or not on the offense charged.
The case focused on the interpretation of Article 91 of the Revised Penal Code regarding the period of prescription and its interruption.

Whether the prescription period for the light threats offense had already lapsed by the time the complaint for light threats was finally filed.

The oral and written motions to quash based on prescription argued that the delay in filing the amended complaint allowed the prescriptive period to run its course.
Consideration was given to the prescribed period of two months (60 days) for the light threats offense as set by Article 90 of the Revised Penal Code.

Whether the delay in amending and filing the complaint, which occurred after the municipal court’s order, should be attributed to factors outside the accused’s control (i.e., the negligence of the prosecution).

Appellant argued that the five-day period granted to file the amended complaint lapsed due to prosecutorial negligence, thus causing an unjustifiable stoppage in the proceedings.
The issue also involved examining whether Medrano’s own motions contributed to the delay and accordingly affected the running of the prescriptive period.

The effect of the municipal court’s discretionary order allowing an amended filing beyond the stated five-day period on the running of the prescription period.

The legal inquiry included whether the court’s acceptance of the late amendment excused the delay and effectively prevented prescription from taking hold.