Case Summary (G.R. No. L-6407)
Facts of the Case
On the morning of January 19, 1952, Bustos encountered Castro while on his way to the barrio chapel for mass. During this interaction, a disagreement erupted, leading to Castro delivering a fist blow to Bustos' face, resulting in injuries that required medical attention for five days. Following this incident, Bustos filed a complaint for slight physical injuries on April 14, 1952, which was subsequently adjudicated in the Justice of the Peace Court of Macabebe. The lower court sentenced Castro to fifteen days of arresto menor and imposed costs. Castro appealed this decision to the Court of First Instance, where he entered a plea of not guilty.
Legal Grounds of the Appeal
During the trial at the Court of First Instance, Castro moved to dismiss the charges on the basis that the crime had already prescribed under Article 90 of the Revised Penal Code, which provides that a light offense prescribes in two months. The crux of the appeal rested on whether the trial court erred in not dismissing the information based on this plea of prescription, as the complaint was filed 86 days after the incident.
Waiver of Defense
The Solicitor General contended that Castro had effectively waived his defense of prescription by failing to file a motion to quash the information prior to pleading. According to Rule 113, Section 10 of the Rules of Court, if an accused does not move to quash before entering a plea, he waives all grounds for quashing the information, except in particular circumstances that do not apply in this case. Nonetheless, the defense argued that the principle of prescription, being a matter of substantive law, should not be subject to procedural waiver.
Application of Legal Precedents
The opinion of the court referenced the case of People vs. Moran, where the Supreme Court had previously allowed the defense of prescription to be raised at any stage, emphasizing that when the State loses its right to prosecute due to prescription, the defendant can seek dismissal of the case irrespective of procedural defaults. The court held that the substantive nature of prescription overrules procedural requirements set by the Rules of Court.
Decision of the Court
In light of the substantive law regarding the prescription of crimes, the court concluded that despite the procedural failure to raise the defense timely, the prescription of the crime could be invoked at any stage of the proceedings. This led to the reversal of the lower court's judgment and the dismissal of the charges against Castro due to the expiration of the statutory limit for prosecution.
Dissenting Opinion
Justice Bengzon, dissenting, argued that the majority opinion undermined the regulatory powers of the court as outlined in the Rules of Court. He maintained that the defense of prescription must be raised withi
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Case Overview
- The case concerns a physical altercation between Apolonio Bustos, the complainant and head teacher of a barrio school, and Pascual Castro, the accused, who was also a teacher at the same institution.
- The incident occurred on January 19, 1952, when Bustos invited Castro to attend mass, leading to a confrontation where Castro struck Bustos, causing injuries that required medical attention for five days.
- Bustos filed a complaint for slight physical injuries on April 14, 1952, which led to Castro’s conviction in the Justice of the Peace Court and a sentence of fifteen days of arresto menor and costs.
Procedural History
- After being convicted in the lower court, Castro appealed to the Court of First Instance, entering a plea of not guilty.
- Prior to the trial on the merits, Castro moved to dismiss the charge, claiming the crime had already prescribed, which the court ignored.
- The Court of First Instance upheld the lower court's penalty after reviewing the evidence.
Legal Issue
- The primary legal question was whether the lower court erred in not dismissing the information based on the ground of prescription, as the alleged offense was filed after the two-month period for light offenses had elapsed.
Prescription of Criminal Liability
- Article 90 of the Revised Penal Code states that light offenses prescribe in two months.
- The complaint was filed 86 days after the incident, exceeding the two-month limitation.
- The Solicitor General argued that Castro wa