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PEOPLE v. MA. THERESA PANGILINAN

FACTS:

The Office of the Solicitor General (OSG) filed a petition for certiorari on behalf of the Republic of the Philippines to nullify and set aside the Decision of the Court of Appeals (CA) in a case entitled "Ma. Theresa Pangilinan vs. People of the Philippines and Private Complainant Virginia C. Malolos." The Decision of the CA reversed the decision of the Regional Trial Court (RTC) of Quezon City and dismissed the criminal cases against Ma. Theresa Pangilinan. The undisputed facts are as follows:

Virginia C. Malolos filed a complaint for estafa and violation of Batas Pambansa (BP) Blg. 22 against Ma. Theresa Pangilinan for issuing checks that were dishonored upon presentment for payment. Respondent then filed a civil case against private complainant before the RTC of Valenzuela City. She also filed a "Petition to Suspend Proceedings on the Ground of Prejudicial Question" on the basis of the pending civil action. The City Prosecutor of Quezon City approved the suspension of the criminal proceedings. However, the Secretary of Justice reversed the resolution and ordered the filing of charges for violation of BP Blg. 22 against respondent. Two counts for violation of BP Blg. 22 were filed before the Metropolitan Trial Court (MeTC) of Quezon City.

Respondent filed a motion to quash the information and defer the issuance of a warrant of arrest. The motion was granted by the MeTC. The private complainant then filed a notice of appeal and the case was raffled to RTC, Branch 218, Quezon City. The RTC reversed the MeTC order and directed the proceedings to proceed. Respondent filed a petition for review with the Supreme Court, which was referred to the CA. The CA reversed the RTC decision, ruling that the cases had already prescribed. The OSG filed a petition for review before the Supreme Court seeking relief.

ISSUES:

  1. Whether the filing of the affidavit-complaint with the Office of the City Prosecutor interrupted the period of prescription of the offense of estafa and violation of BP Blg. 22.

  2. Whether the arguments of the petitioner are anchored on erroneous premises.

  3. Whether the filing of a complaint or information with the fiscal's office suspends the running of the prescriptive period for a criminal offense.

  4. Whether a different rule applies to cases involving special laws.

  5. Whether the proceedings for the prosecution of the accused effectively interrupted the prescriptive period for the offenses charged under BP Blg. 22.

RULING:

  1. The Supreme Court ruled in favor of the petitioner and held that the offense committed by the respondent had not yet prescribed. The filing of the affidavit-complaint with the Office of the City Prosecutor effectively interrupted the period of prescription of the offense. The Court cited Act No. 3326, which governs the prescription period for violations of special laws, including BP Blg. 22. The law provides that the prescription period begins from the day of the commission of the violation and that it is interrupted when proceedings are instituted against the guilty person. Since BP Blg. 22 prescribes in four years, the running of the prescriptive period is tolled upon the institution of proceedings. The Court also rejected the respondent's argument that the cases relied upon by the petitioner involved offenses under the Revised Penal Code and not special laws.

  2. The filing of a complaint or information with the fiscal's office interrupts the period of prescription for a criminal offense, even if the court where the complaint or information is filed cannot try the case on the merits.

  3. There is no distinction between cases under the Revised Penal Code (RPC) and those covered by special laws with respect to the interruption of the prescriptive period.

  4. The commencement of proceedings for the prosecution of the accused before the Office of the City Prosecutor effectively interrupts the prescriptive period for the offenses charged under BP Blg. 22.

PRINCIPLES:

  • The filing of a complaint with the Office of the City Prosecutor interrupts the running of the prescriptive period for offenses under special laws, such as BP Blg. 22.

  • Act No. 3326 governs the prescription period for violations of special laws, including BP Blg. 22.

  • The prescription period for offenses punishable under BP Blg. 22 is four years.

  • The running of the prescriptive period is tolled upon the institution of proceedings against the guilty person.

  • The filing of a complaint or information with the fiscal's office interrupts the prescriptive period for a criminal offense.

  • There is no distinction between cases under the RPC and those covered by special laws with respect to the interruption of the prescriptive period.

  • Commencement of proceedings for the prosecution of the accused before the Office of the City Prosecutor effectively interrupts the prescriptive period for the offenses charged.

  • It is unjust to deprive the injured party of the right to obtain vindication on account of delays that are not under their control.