G.R. No. 43469 - People vs. Yuman

The People of the Philippines filed a Petition for Review on Certiorari challenging the Court of Appeals (CA) Decision dated June 22, 2005, which reversed the Regional Trial Court's (RTC) Order and dismissed the criminal case against respondent Clemente Bautista for slight physical injuries on the ground of prescription.
The CA ruled that although the prescriptive period was interrupted by the filing of the Complaint with the Office of the City Prosecutor (OCP), the offense had prescribed at the time the Information was filed with the Metropolitan Trial Court (MeTC) due to undue delay.

On June 12, 1999, a dispute occurred between respondent Clemente Bautista with his co-accused Leonida Bautista and private complainant Felipe Goyena, Jr.
The complainant initially filed a Complaint with the Barangay of Malate, Manila; mediation failed, and the Barangay chairman issued a Certification to file action on August 11, 1999.
On August 16, 1999, a formal Complaint for slight physical injuries was filed before the OCP against respondent and his co-accused.
After preliminary investigation, the investigating Prosecutor Jessica Junsay-Ong issued a Joint Resolution on November 8, 1999, recommending prosecution through filing of an Information.
The City Prosecutor, through First Assistant City Prosecutor Eufrocino A. Sulla, approved the recommendation; however, the date of approval was not found in the records.
The Information was filed with MeTC only on June 20, 2000, nearly one year after the offense date and about six months into the following year.

The MeTC ruled that the offense had not prescribed.
The RTC denied respondent's petition for certiorari, affirming MeTC’s ruling.
The CA held that the prescriptive period began to run anew after the OCP proceedings were terminated by the approval of the Joint Resolution and since the Information was filed beyond the 60-day prescriptive period starting June 12, 1999, the offense had prescribed.
Consequently, the CA reversed and dismissed the criminal case.

The People of the Philippines filed the present petition seeking reversal of the CA Decision.
The Supreme Court gave due course to the petition, despite no Motion for Reconsideration filed with the CA.

Whether the prescriptive period for slight physical injuries began to run anew after the investigating prosecutor’s recommendation to file an Information was approved by the City Prosecutor.
Whether the delay in filing the Information after the prosecutorial approval resulted in the prescription of the offense charged against respondent Clemente Bautista.