Title
People vs. Court of 1st Instance of Quezon, Branch V, Mauban, Quezon
Case
G.R. No. 41903
Decision Date
Jun 10, 1992
The Supreme Court rules that an information for qualified theft does not need to specify the offended party as long as the criminal act can be properly identified, reversing the lower court's dismissal and remanding the case for further proceedings.
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Case Digest (G.R. No. 41903)

Facts:

  • The case People v. Court of First Instance of Quezon, Branch V, Mauban, Quezon (G.R. No. 41903) involved an information filed on August 5, 1975, against Ramon S. Reyes (alias "Caping"), Guillermo Untalan, Natalio Alvarez, and Wilfredo Saliendra.
  • The respondents were charged with qualified theft under Presidential Decree No. 330.
  • The alleged offense occurred on April 16, 1974, in Barrio San Jose, Mauban, Quezon, where the respondents unlawfully entered a public forest leased to Aluk Logging Corporation and cut down two Lauan trees valued at P1,920.00.
  • After pleading not guilty during their arraignment on September 17, 1975, the respondents filed a motion to quash the information, claiming it lacked a proper offended party and other deficiencies.
  • The Provincial Fiscal opposed the motion, arguing the information was sufficient and could be amended for a typographical error.
  • On October 24, 1975, the Court of First Instance dismissed the information, citing the failure to specify the offended party as a substantial defect.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioner, reversing the lower court's dismissal of the information for qualified theft.
  • The Court determined that the information was sufficient in both form and substance, and the omission of the State as the offended ...(Unlock)

Ratio:

  • The Supreme Court emphasized that prosecuting crimes is a sovereign function, and criminal actions must be initiated in the name of the People of the Philippines.
  • The Court found that the information met legal requirements as it was filed in the name of the People, thus properly initiating prosecution.
  • The lower court's reasoning regarding the absence of the State as the offended party was rejected.
  • The Court cited Sayson v. People, which established that in ...continue reading

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