G.R. No. L-17616 - People vs. Abuy

On February 21, 1959, Felipe Abuy allegedly committed acts that led to two separate criminal charges in Zamboanga City.
The first charge was for trespass to dwelling, based on allegations of unlawfully entering Ruperto Carpio’s dwelling without consent.
The second charge, filed later, was for unjust vexation, where Abuy was alleged to have intentionally embraced and grabbed the wrist of Nicolasa (also referred to as Michaela) B. de Magadia in her dwelling.

The information for trespass to dwelling was filed on April 1, 1959 with a charge stating that Abuy entered Carpio’s dwelling on February 21, 1959.
During arraignment, Abuy pleaded not guilty, and the trial commenced.
On November 5, 1959, while the trial was still in progress, the prosecution moved to dismiss the information on the ground that the evidence presented was insufficient to sustain a conviction.
The Municipal Court granted the motion, resulting in Abuy’s acquittal, the cancellation of his bail bond, and the closing of the trespass to dwelling case.

Following the dismissal of the trespass case, on November 13, 1959, Abuy was charged with unjust vexation.
The second information alleged that on the same day of February 21, 1959, Abuy had, with intent to cause vexation, unlawfully embraced and grasped the wrist of Nicolasa B. de Magadia in her dwelling.
Abuy filed a motion to quash this information on the ground that the crime of unjust vexation had already prescribed, and this motion was supported by the defense attorney.

The Municipal Court granted the motion to quash, basing its decision on the fact that unjust vexation is a light offense that prescribes within two months.
The court highlighted that the information for unjust vexation, filed on November 13, 1959, stated that the offense occurred on February 21, 1959—making the filing approximately 6 months and 20 days after the alleged commission.
The court contrasted the procedural differences between the two informations, noting that the filing of the trespass information did not legally interrupt the running of the prescriptive period for unjust vexation because the charges involved different offenses with distinct elements.
The prosecution later appealed the municipal court’s decision, but the Court of First Instance of Zamboanga City denied the appeal on July 30, 1960, labeling it unmeritorious and unfounded.
The appellate decision affirmed that the prescription period for unjust vexation had elapsed, and therefore, the subsequent charging was legally untenable.

Whether the crime of unjust vexation, being a light offense that prescribes within two months, had indeed prescribed by the time the information was filed on November 13, 1959.
Whether the alleged acts on February 21, 1959, were subject to a prescriptive period that had already lapsed at the time of filing.

Whether the filing of the information for trespass to dwelling (a distinct offense) could be considered as interrupting the running of the prescriptive period for the offense of unjust vexation.
Whether the separate nature of the two charges negated any legal effect that filing one might have on the prescriptive period of the other.

Whether the trial court’s dismissal of the trespass to dwelling charge and the subsequent charging for unjust vexation, despite involving the same factual episode, was procedurally acceptable.
Whether there was any reversible error in the court’s handling of the motions and the subsequent denial of the prosecution’s appeal.