Case Digest (G.R. No. 207735) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Mateo A. Lee, Jr., G.R. No. 234618, decided December 14, 2020, the Office of the Special Prosecutor (OSP) of the Office of the Ombudsman filed an Information on March 21, 2017 in the Sandiganbayan’s Third Division charging Deputy Executive Director Mateo Acuin Lee, Jr. with violation of Republic Act No. 7877 (Anti-Sexual Harassment Act of 1995). The complaint alleged that between February 14, 2013 and March 20, 2014, Lee, by exploiting his position, repeatedly demanded sexual favors from his subordinate, Administrative Aide VI Diane Jane Paguirigan, creating an intimidating and hostile work environment. Lee moved for outright dismissal on the ground of prescription, which the Sandiganbayan denied in its June 2, 2017 Resolution. Upon Lee’s motion for reconsideration, the court reversed itself on September 6, 2017 and dismissed the case as prescribed. The OSP’s subsequent motion for reconsideration was denied on October 6, 2017. The People then file Case Digest (G.R. No. 207735) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- The People of the Philippines, through the Office of the Special Prosecutor (OSP) of the Office of the Ombudsman, filed a Petition for Review under Rule 45.
- Mateo Acuin Lee, Jr. (respondent) was the Deputy Executive Director of the National Council on Disability Affairs.
- Criminal Information and Allegations
- On March 21, 2017, an Information for Violation of Republic Act No. 7877 (Anti-Sexual Harassment Act of 1995) was filed before the Sandiganbayan.
- The Information alleged that from February 14, 2013 to March 20, 2014, Lee abused his position to demand sexual favors from Diane Jane M. Paguirigan, creating a hostile work environment.
- Pretrial Motions and Sandiganbayan Resolutions
- Lee’s Motions
- On March 30, 2017, Lee filed a Motion for Judicial Determination of Probable Cause and Prescription Extinguishing Criminal Liability, praying for outright dismissal.
- On June 29, 2017, Lee’s counsel filed a Motion for Reconsideration of the June 2, 2017 Resolution that denied the March 30 motion.
- OSP’s Oppositions
- The OSP opposed Lee’s March 30 motion on April 17, 2017.
- The OSP opposed Lee’s June 29 motion.
- Sandiganbayan Rulings
- June 2, 2017 Resolution denying Lee’s motion for dismissal.
- September 6, 2017 Resolution granting Lee’s motion for reconsideration and dismissing the case on ground of prescription.
- October 6, 2017 Minute Resolution denying the OSP’s motion for reconsideration.
- Petition for Review and Petitioner’s Contentions
- The People contend the Sandiganbayan erred in applying Jadewell v. Lidua (prescription for ordinances) instead of special-law jurisprudence.
- The People argue that under People v. Pangilinan and Panaguiton Jr. v. DOJ, the filing of the complaint with the prosecutor’s office (or Ombudsman) tolled the prescriptive period for special laws.
- Respondent’s Procedural Objections
- Lee challenged the Petition’s lack of clear dates for receipt of the SB resolution and filing of motions for reconsideration.
- He alleged defects in the certification against forum shopping and the verification’s signatories’ authority.
Issues:
- Whether the Sandiganbayan correctly dismissed the Information against Lee on the ground of prescription of the offense.
- Whether the filing of the Affidavit-Complaint before the Office of the Ombudsman on April 1, 2014 tolled the three-year prescriptive period for violation of RA 7877.
- Whether the Sandiganbayan misapplied Jadewell v. Lidua, a jurisprudence on municipal ordinances, instead of controlling special-law doctrine.
- Whether the Petition’s alleged defects in verification and certification against forum shopping warrant its dismissal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)