G.R. No. L-7617 - People vs. Yanga

The case is an appeal from the People of the Philippines (plaintiff and appellee) against Pelagio G. Yanga (defendant and appellant).
The appellant was convicted of unjust vexation, ultimately sentenced to 20 days of arresto menor and ordered to pay the costs.

On October 10, 1951, an information for light threats was filed against the appellant in the Municipal Court of Manila.

The information alleged that on or about October 4, 1951, the accused willfully, unlawfully, and feloniously threatened one Cristeto Remigio by pointing a revolver at him, even though such action was not necessary for lawful self-defense.
The accused entered a plea of not guilty to this information.

On June 1, 1952, the private prosecutor moved for the dismissal of the light threats information.

The motion was based on the filing of a separate information for grave coercion.
This second information, filed on May 21, 1952, in the Court of First Instance of Manila and later amended on May 26, 1952, charged that on October 4, 1951, the accused, without authority of law and by means of violence, compelled Cristeto Remigio to act against his will by holding him around the neck and dragging him from his residence to a police outpost.

The material allegations in the light threats information involved the act of threatening by pointing a revolver.
The grave coercion information, on the other hand, charged the use of violence—holding and dragging the victim—which are distinct elements from a mere threat.

The appellant contended that dismissing the light threats case after he had pleaded not guilty should bar the subsequent prosecution for grave coercion, arguing that he was being placed twice in jeopardy for the same act.
The appellant also claimed that the crime of unjust vexation (and by extension, the underlying criminal act) had already prescribed due to the short two-month prescriptive period for light offenses under Article 90 of the Revised Penal Code.

Despite light offenses prescribing in two months, the filing of the information on October 10, 1951, served to interrupt the prescriptive period.
The later filing of information for grave coercion on May 21, 1952, occurred within the period of interruption.
Consequently, the claim of prescription based on the two-month rule was determined to be without merit.

The trial court dismissed the initial information for light threats following the motion by the private prosecutor, notwithstanding the appellant’s objection.
The evidence supporting the conviction for light threats was deemed insufficient to sustain a conviction for grave coercion.
The trial court ultimately found that there was no instance of double jeopardy since the two charges were based on different material allegations and distinct legal elements.

Whether the dismissal of the light threats information, after the appellant had entered a plea of not guilty, constitutes double jeopardy by barring a subsequent prosecution for grave coercion.

Analysis of whether the acts charged under each information were sufficiently identical or distinct.
Consideration of the principle that a single act may give rise to different offenses if the alleged elements differ materially.

Whether the criminal act with which the appellant was charged had already prescribed under the rule for light offenses, given the two-month prescriptive period and the effect of the interruption caused by the filing of the initial information.

Examination of the prescriptive period in relation to the chronological filing of the information for light threats.
Determination of whether the filing of a subsequent information for grave coercion continued the interruption and thus prevented prescription.

Whether the evidence presented in support of the charge of light threats could suffice for a conviction for grave coercion.

Consideration of the legal differences between the offense of light threats and that of grave coercion.
Assessment of whether the differing elements in the charges change the nature of the offense to avoid the bar of double jeopardy.