Case Summary (G.R. No. L-9598)
Relevant Dates
The offense is alleged to have occurred on June 26, 1954, with the information filed against Yu Hai on October 22, 1954. The Supreme Court decision was delivered on August 15, 1956.
Applicable Law
The decision primarily relies on the Revised Penal Code of the Philippines, particularly focusing on Articles 90, 9, and 26, which outline the prescription periods for various offenses and define the categories of felonies.
Summary of Proceedings
Yu Hai was accused of violating Article 195, sub-paragraph 2 of the Revised Penal Code by allowing and maintaining the game of panchong or paikiu, categorized as a game of hazard. Following the filing of the information, Yu Hai sought to quash the charges, asserting that the case involved more than one offense and that the liability had already lapsed due to prescription. The Justice of the Peace Court upheld the motion, considering it a light offense that prescribed in two months according to Article 90 of the Penal Code.
Issues on Appeal
The case escalated to the Court of First Instance when the provincial fiscal appealed the dismissal. The lower court confirmed the order of the Justice of the Peace Court, leading to the present advisement of the Supreme Court. The primary issue under consideration is the applicable period for the prescription of the offense.
Legal Interpretation of Prescription
Under Article 90 of the Revised Penal Code, offenses punishable by fines not exceeding P200 are classified as light offenses, which prescribe in two months. The Solicitor General contended that the charge carries a maximum fine of P200, classifying it as a correctional penalty and thereby subjecting it to a ten-year prescription period. However, the Supreme Court found this argument flawed, emphasizing that Article 90 must be interpreted in conjunction with Article 9, which expressly defines light felonies.
Court's Reasoning on Offense Classification
The Supreme Court reasoned that an inconsistency in interpretation could lead to absurd outcomes, such as varying prescriptive periods based on minor distinctions in penal classification. It was highlighted that the law does not intend for a one-peso difference in fines to substantially alter the period of prescription. As the charge falls under the category of light offense, subject t
...continue readingCase Syllabus (G.R. No. L-9598)
Case Overview
- The case involves the appeal of the provincial fiscal against the dismissal of an information charging Yu Hai, alias "Haya," with a violation of Article 195, sub-paragraph 2 of the Revised Penal Code.
- The charge pertained to the alleged maintenance of the game of panchong or paikiu in Caloocan on June 26, 1954.
- The accused filed a motion to quash the information, arguing it charged more than one offense and that the liability had already expired due to prescription.
Legal Proceedings
- The Justice of the Peace Court of Caloocan granted the motion to quash on December 24, 1954, reasoning that the alleged offense was a light offense with a two-month prescription period under Article 90 of the Revised Penal Code.
- The provincial fiscal appealed the decision to the Court of First Instance, which upheld the dismissal of the information.
Issue at Hand
- The primary issue before the Supreme Court was the determination of the prescription period for the offense charged under Article 195 of the Revised Penal Code.
- The lower court classified the offense as a light offense subject to a two-month prescription, whil