Case Summary (G.R. No. 198010)
Jurisdiction and Applicable Law
The case was originally prosecuted in the Municipal Court of Manila under the Revised Penal Code, particularly addressing issues of double jeopardy and the prescription of criminal offenses. The applicable law for this decision is rooted in the provisions of the Revised Penal Code that govern the prescription of offenses and double jeopardy.
Background of the Case
On October 10, 1951, Pelagio G. Yanga was charged with light threats for allegedly threatening Cristeto Remigio by pointing a revolver at him. The appellant pleaded not guilty to the charges. Subsequently, on June 1, 1952, the private prosecutor moved to dismiss this charge, citing that a separate charge of grave coercion had already been filed against Yanga in the Court of First Instance of Manila on May 21, 1952. The Municipal Court dismissed the light threats charge on June 12, 1952.
Charges and Dismissals
The information for grave coercion, which was filed after the initial complaint for light threats, detailed several acts of violence against Remigio, including physically compelling him against his will. The substantive differences between the two charges are significant: the charge of light threats centers around the act of intimidation (pointing a revolver), while grave coercion involves physical force to compel action.
Argument on Double Jeopardy
Yanga contended that the dismissal of the light threats charge acted as a bar to the prosecution for grave coercion, asserting that the crimes were essentially the same. The court analyzed the material elements of both offenses and determined that the crimes are distinct. Since the evidence required for a conviction of light threats does not support a conviction for grave coercion, the principle of double jeopardy was not violated.
Prescription of Offense
Regarding Yanga's claim that the crime of unjust vexation had prescribed, the court clarified that light offenses, including unjust vexation, have a prescription period of two months. The court recognized that the filing
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Case Overview
- This case involves an appeal certified by the Court of Appeals concerning the conviction of Pelagio G. Yanga for the crime of unjust vexation.
- The judgment rendered by the lower court sentenced Yanga to 20 days of arresto menor and imposed costs.
- The appellant contends that the trial court erred by not recognizing that he had been placed twice in jeopardy and that the crime charged had already prescribed.
Background of the Case
- On October 10, 1951, Yanga was charged in the Municipal Court of Manila with light threats, stemming from an incident on October 4, 1951.
- The charge alleged that Yanga threatened Cristeto Remigio by pointing a revolver at him, which was not necessary for lawful self-defense.
- Yanga entered a plea of not guilty to this charge.
Motion to Dismiss
- On June 1, 1952, the private prosecutor moved to dismiss the information for light threats, citing the filing of another case for grave coercion against Yanga on May 21, 1952.
- The Municipal Court dismissed the information for light threats on June 12, 1952, despite Yanga's objection.
Information for Grave Coercion
- The information for grave coercion was filed on May 21