Case Summary (G.R. No. L-24364)
Summary of Proceedings
On November 29, 1963, a criminal complaint was lodged against Medrano for allegedly making threats against Argente on September 30, 1963. Medrano’s defense sought to quash the complaint on the grounds that it did not conform to the prescribed form and charged multiple offenses. Initially, the Municipal Court denied the motion, but later permitted an amendment to the complaint, requiring the private prosecutor to charge only the offense of light threats. This amended complaint, however, was not filed until April 15, 1964, exceeding the five-day timeframe set by the court.
Prescription of Action
On April 23, 1964, Medrano filed a motion to quash the amended complaint, claiming that the complaint had prescribed. The basis for his argument was Article 91 of the Revised Penal Code, which states the prescription period for light offenses is 60 days. The court had to determine when the prescription period began and whether it had been interrupted by the procedural actions taken.
Court of First Instance Decision
The Court of First Instance of Batangas reviewed Medrano's petition and dismissed it, prompting Medrano to appeal on the legal question regarding the application of prescription. Central to the court's analysis was whether the filing delay of the amended complaint constituted an unjustifiable stoppage of proceedings and whether it should restart the prescription period.
Interpretation of Prescription Law
The court found that the prescription period for light threats began on September 30, 1963, when the threats were made. Although the amended charge was filed after the five-day period, the court held that the municipal court retained discretion to accept late filings, especially since the delay was influenced by Medrano's own actions in seeking to quash the original complaint. The court reasoned that Medrano was instrumental in the procedural delays, thus negating his claim of unjustifiable stoppage.
Affirmation of the Lower Court's Decision
Ultimately, the appellate court affirmed the lower court's judgment, holding there was no abuse of discretion. The acceptance of the delayed amended charge was aligned with legal standards, and the delay could not be attributed to the prosecution alone. The court noted Medrano&#
...continue readingCase Syllabus (G.R. No. L-24364)
Case Overview
- The case involves a criminal complaint lodged against petitioner-appellant Bienvenido Medrano for allegedly committing light threats against Leonardo Argente on September 30, 1963.
- The complaint was filed in the Municipal Court of Ibaan, Batangas on November 29, 1963, and the appellant subsequently moved to quash the complaint on two grounds.
- The municipal court initially denied the motion but later required the private prosecutor to amend the complaint to charge only light threats.
Procedural History
- The municipal court issued an order on March 14, 1964, granting the private prosecutor five days to amend the complaint.
- The private prosecutor received this order on March 18, 1964, but the amended complaint was only filed on April 15, 1964.
- On April 23, 1964, the appellant filed a motion to quash the amended complaint, citing prescription.
- The municipal court denied this motion, prompting the appellant to petition the Court of First Instance of Batangas for prohibition.
Legal Issues Raised
- The primary legal issue centers around whether the prescription period for filing the complaint had set in, as outlined in Article 91 of the Revised Penal Code.
- The appellant contended that the period of