G.R. No. 48707-48709 - People vs. Tayco

The People of the Philippines is the plaintiff and appellant.
Victor Tayco is the defendant and appellee.
The offense charged is unjust vexation, a light offense punishable under the second paragraph of Article 287 of the Revised Penal Code.

Unjust vexation was allegedly committed by the defendant against three individuals:

May 5, 1941 – incident involving at least one offended party (inferred for one or more).
May 6, 1941 – additional incidents involving the offended parties.
May 2, and again May 6, 1941 – further identification of the dates related to these complaints.

The offended parties reported their grievances to the City Fiscal on May 24, 1941.
The Municipal Court received and filed the corresponding information on July 10, 1941, which is more than two months after the commission and discovery of the offense.

The defendant, Victor Tayco, filed a motion to quash the complaint before the Municipal Court, which was denied.
On appeal, the Court of First Instance (Judge Jose R. Carlos presiding) dismissed the three cases on the ground that the offense had prescribed.
The City Fiscal subsequently appealed the dismissal to the Supreme Court, seeking to reverse the decision on the merits of the prescription issue.

Article 287 of the Revised Penal Code – Punishment for unjust vexation is provided as arresto menor or a fine ranging from P5 to P200, or both.
Article 90 of the Revised Penal Code – Specifies that light offenses prescribe in two months.
Article 91 of the Revised Penal Code – Details that the prescriptive period is interrupted only by the filing of the complaint or information in the proper court, not merely by a report or complaint lodged in the City Fiscal’s office.
Section 2465 of the Revised Administrative Code – Grants the City Fiscal the power to investigate charges and prepare necessary information, but does not confer the power to interrupt the prescription period as defined by Article 91.

Whether the filing of a report by the offended parties with the City Fiscal’s office is equivalent to the filing of a formal complaint or information in a proper court.

Can the mere act of reporting the crime to a fiscal authority interrupt the prescriptive period outlined in Article 91 of the Revised Penal Code?

Whether the delay in the formal filing of the information (from May 24, 1941, to July 10, 1941) exceeds the prescribed two-month period for light offenses, thus rendering the cases time-barred.

Does the time lapse between the discovery/reporting of the crime and the filing in the Municipal Court invoke the prescription provisions?

Whether the City Fiscal’s reliance on Section 2465 of the Revised Administrative Code to equate a preliminary investigation with the judicial process is legally tenable in interrupting the running of the prescriptive period.

Is the interpretation that the act of lodging a complaint with the fiscal legal office satisfies the interruption requirement under Article 91 of the Revised Penal Code valid?