Case Digest (G.R. No. 210504)
Facts:
On October 22, 1954, Yu Hai, also known as "Haya," was accused in the Justice of the Peace Court of Caloocan of violating Article 195, sub-paragraph 2 of the Revised Penal Code, which pertains to the unauthorized maintenance of the game panchong or paikiu, categorized as a game of chance. This alleged infraction occurred on June 26, 1954. Yu Hai moved to quash the information on two grounds: first, that it charged more than one offense, and second, that the criminal action had been extinguished due to the expiration of the statute of limitations. The Justice of the Peace Court granted the motion to quash on December 24, 1954, determining that the offense was a light offense that had a statutory prescription period of two months as per Article 90 of the Revised Penal Code. The provincial fiscal subsequently appealed this decision to the Court of First Instance, which upheld the dismissal of the information. The provincial fiscal then escalated the matter directly to the Supreme CCase Digest (G.R. No. 210504)
Facts:
- Incident and Charge
- On October 22, 1954, Yu Hai, also known as "Haya", was charged in the Justice of the Peace Court of Caloocan.
- The charge stemmed from an alleged violation of Article 195, sub-paragraph 2 of the Revised Penal Code for permitting and maintaining the game of panchong (also called paikiu), a game of hazard, in Caloocan.
- Allegations and Dates
- The offense was said to have been committed on or about June 26, 1954.
- The charge pertained to an infractions classified under the provisions governing light offenses.
- Pre-Trial Motions and Lower Court Proceedings
- Yu Hai filed a motion to quash the information on the grounds that it charged more than one offense and that the criminal liability had already been extinguished.
- On December 24, 1954, the Justice of the Peace Court granted the motion to quash, basing its ruling on the theory that the offense—a light offense prescribing in two months under Article 90 of the Revised Penal Code—had already prescribed.
- Prosecution’s and Appellate Actions
- The provincial fiscal, disagreeing with the quashing, appealed the decision to the Court of First Instance of the province.
- The Court of First Instance affirmed the lower court’s dismissal largely on prescription grounds.
- The provincial fiscal then directly appealed to the Supreme Court to contest the dismissal and the interpretation of the prescriptive period applicable to the offense.
Issues:
- Classification of the Offense
- Whether the charged offense qualifies as a “light offense” under Article 9 of the Revised Penal Code, as it is punishable by arresto menor or a fine not exceeding 200 pesos.
- The implication of this classification in determining the prescriptive period.
- Determination of the Appropriate Prescriptive Period
- Whether the offense should prescribe in two months, as provided for light offenses under Article 90 of the Revised Penal Code.
- Whether an alternative reading—based on the argument that a fine of up to 200 pesos constitutes a correctional penalty (per Article 26) and hence prescribes in ten years—is tenable.
- Interpretation and Hierarchy of Statutory Provisions
- How Article 90, which provides specific prescriptive periods for light offenses, should be applied compared to the penalty classification in Article 26.
- The proper method of reconciling the apparent conflict between the prescription periods based on different interpretative bases (i.e., offense classification versus fine classification).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)