Facts:

• The case involves the People of the Philippines (plaintiff and appellant) against Dolores Coquia (defendant and appellee).
• On July 1, 1957, David C. Naval filed a complaint for grave oral defamation against Coquia in the Municipal Court of Naga.
• The court ordered Coquia's arrest following the complaint.
• On July 22, 1957, the Municipal Court forwarded the case records to the Court of First Instance of Camarines Sur after Coquia waived her right to a second stage of preliminary investigation.
• The case remained inactive until January 26, 1959, when the City Fiscal filed the information for grave oral defamation against Coquia.
• Coquia filed a Motion to Dismiss, claiming the case had prescribed.
• The prosecution opposed the motion.
• The lower court ruled in favor of Coquia, dismissing the case due to prescription.
• The City Attorney, represented by the Solicitor General's Office, appealed the decision to the Supreme Court, acknowledging the delay in filing.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the lower court's decision to dismiss the case on the grounds of prescription.
• The Government's appeal was dism...(Unlock)

Ratio:

• The Supreme Court determined that the prescriptive period for grave oral defamation, set at six months by Article 90 of the Revised Penal Code, was not interrupted in this case.
• The filing of the information occurred more than a year after the incident, exceeding the statutory period for prescription.
• The Court referenced the case of People vs. Juan del Rosario, whic...continue reading