G.R. No. L-47646 - People vs. Maravilla

On April 29, 1977, the alleged incident occurred when Manuel B. Gadon, a lawyer, reportedly grabbed the left breast of Remy G. Gomboc, a 24‐year–old saleslady, against her will.
Gomboc testified that the nonconsensual act caused her shock, indignation, and shame, and that she retaliated by giving Gadon an angry kick, which did not connect as intended, prompting him to flee.

On May 10, 1977, a complaint for acts of lasciviousness was filed by Gomboc in the municipal court of San Andres, Romblon. This case was docketed as Criminal Case No. 1995.
In the temporary absence of the municipal judge, the municipal mayor conducted the preliminary investigation, issuing a warrant of arrest and setting bail at ₱4,000.00, which was immediately posted by the accused.

On July 1, 1977, the municipal judge dismissed the case by annulling the preliminary investigation and the warrant of arrest due to the mayor’s failure to ask the required “searching questions” under the Rules of Court.
On July 13, 1977, the complainant re-filed her charge of acts of lasciviousness in Criminal Case No. 1998.
On July 19, 1977, after conducting a further preliminary investigation, the municipal judge ruled that there was no prima facie evidence of the crime as originally charged and instructed the prosecution to file the proper charge as warranted by the evidence.

On July 21, 1977, based on the evidence presented, the charge was amended from acts of lasciviousness to unjust vexation, and the case was docketed as Criminal Case No. 2000.
The accused pleaded not guilty and moved to quash the case on the ground that the crime had prescribed.
Following an exchange of memoranda between the defense and prosecution, the municipal judge issued an order on October 11, 1977, granting the motion to quash and dismissing the case.
A motion for reconsideration was filed but subsequently denied on November 9, 1977.

The case involves the interpretation of Article 91 of the Revised Penal Code, which provides for the computation and interruption of the period of prescription by the filing of a complaint or information.
The respondents argued that the prescriptive period started on April 29, 1977, ran uninterrupted until July 21, 1977 (83 days in total), and thus, the prosecution was barred by prescription.
In contrast, the petitioner maintained that the prescriptive period was interrupted by the valid filing of the complaint, even if initially done with the municipal mayor in the absence of a judge, and that the subsequent proceedings did not amount to a lapse of time sufficient to bar the charge of unjust vexation.

Whether the filing of the complaint with the municipal mayor (acting as an authorized officer in the temporary absence of a judge) effectively interrupted the running of the prescriptive period under Article 91 of the Revised Penal Code.

Whether the change of the charge from acts of lasciviousness to unjust vexation, based on the complainant’s description in the allegations, is valid for the purposes of computing the prescriptive period.

Whether the series of dismissals and re-filings, from the original complaint to the amended charge, affected the suspension or resumption of the prescriptive period, thereby impacting the prosecution’s ability to proceed.