Case Summary (G.R. No. L-13106)
Procedural History
On August 1, 1952, Demetria Somod-ong filed her complaint in the Justice of the Peace Court in Oroquieta, Misamis Occidental, leading to Criminal Case No. 3415. The initial investigation initiated by the court resulted in the elevation of the case to the Court of First Instance after finding probable cause. However, a clerical mistake occurred when Pastora Somod-ong was erroneously identified as the offended party, which ultimately led to the dismissal of the case.
Supreme Court Ruling on Initial Dismissal
The Government appealed to the Supreme Court, which upheld the trial court’s dismissal due to the variant allegations. In People vs. Juliana Uba and Calixta Uba, the Supreme Court concluded that the evidence indicated the Uba sisters were guilty of defamation against Demetria Somod-ong, prompting a directive for the Provincial Fiscal to file a new information correctly identifying Demetria as the offending party.
Filing of Second Complaint and Trial Court Dismissal
The Provincial Fiscal subsequently filed a new complaint on June 12, 1956, under Criminal Case No. 4239, targeting the Uba sisters for the serious oral defamation against Demetria Somod-ong. The defense counsel moved for dismissal on the grounds of double jeopardy and prescription. The trial court, without ruling on double jeopardy, dismissed the case on September 5, 1957, citing the expiration of the six-month prescription period per Article 90 of the Revised Penal Code, claiming that the crime had prescribed since more than four years elapsed from the date of the alleged offense.
Analysis of Prescription Period
The trial court's dismissal, however, overlooked Article 91 of the Revised Penal Code, which pertains to the computation of the prescription of offenses. The pertinent clause states that the prescriptive period starts from when the crime is discovered and is interrupted upon the filing of a complaint. In this instance, from July 25, 1952, to August 1, 1952, only seven days had elapsed until the complaint was lodged. Following the Supreme Court’s decision on Ma
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Case Overview
- The case involves an appeal by the Government against the decision of the Court of First Instance of Misamis Occidental, which dismissed a complaint for serious oral defamation against Juliana Uba and Calixta Uba based on the ground of prescription.
- The original complaint was filed by Demetria Somod-ong on August 1, 1952, for defamation allegedly committed against her on or before July 25, 1952.
Procedural History
- The case began in the Justice of the Peace Court of Oroquieta, Misamis Occidental, where a complaint was filed charging the accused with serious oral defamation.
- The court found probable cause, and the case was escalated to the Court of First Instance, where the Provincial Fiscal filed the corresponding information.
- An error occurred when Pastora Somod-ong was mistakenly designated as the offended party instead of Demetria Somod-ong, leading to the dismissal of the case by the trial court.
- The Government appealed the dismissal to the Supreme Court, which affirmed the order but noted that the accused were guilty of insulting Demetria Somod-ong and directed the Provincial Fiscal to file a new informatio