Case Summary (G.R. No. 74689)
Factual Background
The case revolves around a petition filed by Roberto R. Benedicto, who seeks a prohibition and mandamus to annul orders from the Regional Trial Court that denied his motions to quash a criminal case against him. Benedicto had operated a trucking business since March 1971 and employed Salvador Pillon but failed to report this employment to the SSS or remit contributions. After Pillon's death in 1975, the SSS began investigating Benedicto's compliance with the Social Security Act and subsequently initiated criminal proceedings against him in 1985, citing violations related to his failure to register Pillon for SSS coverage.
Legal Proceedings
Before arraignment, Benedicto moved to quash the information against him, claiming that the charges had already prescriptive. The SSS opposed this motion, arguing that the prescriptive period for such violations was twenty years, as stipulated in the relevant provisions of the Social Security Act. The trial court denied Benedicto's motion, stating that the 20-year period applied to his case.
Central Legal Issues
The primary legal question is whether the criminal charge filed against Benedicto had prescribed. Benedicto contended that the 20-year prescriptive period mentioned in Section 22(b) of the Social Security Act pertains only to administrative or civil actions, asserting that a four-year prescription under Act No. 3326 should apply instead.
Analytical Framework
The court examined the relevant provisions of the Social Security Act and Act No. 3326, determining that the provisions in Section 22(b) do not explicitly address criminal sanctions but focus on civil and administrative collection of contributions. The court analyzed the placement of the prescriptive period within the law and the nature of the actions it governs.
Court's Findings
The court ultimately found it difficult to accept the SSS's position that the 20-year period applied to both civil and criminal actions. The 20-year prescriptive period described was designed for the collection of delinquent contributions and had no direct bearing on the penal consequences for criminal violations. Therefore, the court concluded that the crime charged had indeed prescribed, as the information was filed ten years after the alleged violations were discovered, exceeding the applicable four-year statute of limitations for criminal liabilities.
Distinction Between Civil and Criminal Liabilities
The court clarified that while the criminal prosecution against Benedicto was dismissed due to prescription, this did not affect any civil liabilities stemming from the same
...continue readingCase Syllabus (G.R. No. 74689)
Case Overview
- Petitioner: Roberto R. Benedicto
- Respondents: Hon. Quirino D. Abad Santos, Jr. (Presiding Judge), Social Security System (SSS)
- Case Reference: G.R. No. 74689
- Decision Date: March 21, 1990
- Court: Supreme Court of the Philippines, Third Division
- Type of Petition: Petition for Prohibition and Mandamus with Preliminary Injunction
Background Facts
- Roberto R. Benedicto commenced a trucking business in March 1971, employing Salvador Pillon as a truck driver.
- Benedicto failed to report Pillon’s employment to the SSS and did not remit the required contributions.
- The SSS became aware of this noncompliance in 1975, following Pillon's death.
- An investigation was initiated by the SSS, leading to Benedicto admitting his failure to register Pillon and remit contributions, resulting in an assessment of P491.70 in unpaid premiums.
- A criminal information was filed against Benedicto on July 18, 1985, for violations of the Social Security Act.
Legal Proceedings
- Initial Response: Benedicto filed a Motion to Quash the information, claiming that his liability had already prescribed.
- SSS Opposition: The SSS contended that the 20-year prescriptive period applied and that the action was still within this time frame.
- Trial Court Ruling: The respondent judge denied the Motion to Quash, asserting that the prescriptive period was indeed 20 years as indicated in Section 22(b) of the Social Security Act.
Central Issue
- The key issue for determination was whether the criminal charge against Benedicto had prescribed, focusing on the applicable statute of limitations for the