Case Summary (G.R. No. L-25174)
Applicable Law
The case primarily deals with Republic Act No. 6713, alongside Act No. 3326, which governs the prescription of violations concerning special acts and municipal ordinances. Specifically, the Court examined stipulations regarding the eight-year prescriptive period for certain offenses as mentioned in Act No. 3326.
Antecedents of the Case
In 2004, the General Investigation Bureau-A of the Office of the Ombudsman initiated a complaint against Del Rosario for failing to file her SALNs for the years 1990 and 1991, including allegations of dishonesty and grave misconduct. Following this, two criminal charges were filed against her by the Office of the Ombudsman in the Metropolitan Trial Court (MeTC). Del Rosario subsequently submitted a Motion to Quash, arguing that the offenses had already prescribed.
Judicial Proceedings
The MeTC granted Del Rosario's Motion to Quash, which was later upheld by the Regional Trial Court (RTC). However, the State appealed to the Sandiganbayan, which ultimately overturned the RTC's decision, ruling that the prescriptive period began from the discovery of the non-filing of the SALNs rather than from the date of omission.
Core Issue Presented
The central issue for resolution in this case was whether the eight-year prescriptive period for the crimes attributed to Del Rosario should commence from her failure to file the SALN or from the point at which the violation was discovered by authorities.
Ruling of the Court
The Supreme Court determined that the prescriptive period for violations of R.A. No. 6713 should not apply the "discovery rule" as claimed by the Sandiganbayan. The Court explained that Section 8 of R.A. No. 6713 clearly mandates submission deadlines for SALNs, but does not explicitly state a prescriptive period for its violation. Thus, the prescriptive period should be governed by Act No. 3326, which prescribes an eight-year period for violations punishable with imprisonment of two years and above, starting from the date of commission, unless there is reasonable cause to apply the discovery rule.
Application of Prescription Periods
In this case, the Court held that the complaint against Del Rosario, initiated in 2004, was filed long after the expiration of the eight-year prescription period as the deadlines for the SALNs in question were Ap
...continue readingCase Syllabus (G.R. No. L-25174)
Case Overview
- The case revolves around Melita O. Del Rosario's alleged violation of Section 8 of Republic Act No. 6713, concerning her failure to file detailed sworn Statements of Assets, Liabilities, and Net Worth (SALNs) for the years 1990 and 1991.
- The primary legal question is whether the eight-year prescriptive period for the offense should commence from the date of filing the SALNs or from the discovery of the non-filing.
Background of the Case
- On October 28, 2004, the Office of the Ombudsman charged Del Rosario for violations related to the non-filing of her SALNs, alongside other charges of dishonesty and grave misconduct.
- The criminal charges were formally filed in the Metropolitan Trial Court (MeTC) on March 11, 2008, leading to two specific criminal cases against her for the years 1990 and 1991.
- Del Rosario filed a Motion to Quash the informations, arguing that the offenses had already prescribed.
- The MeTC initially granted the Motion to Quash on September 18, 2009, a decision that was upheld by the Regional Trial Court (RTC).
Legal Framework
- Republic Act No. 6713 mandates public officials to file SALNs annually by April 30.
- The law does not specify a prescriptive period for violations, leading to the application of Act No. 3326, which outli