The United States v. Ambrosio Tiqui

Summary

This landmark 1902 Supreme Court case established the fundamental rule for computing appeal periods in Philippine jurisprudence. When the United States appealed a criminal case against Ambrosio Tiqui, the defense moved to dismiss arguing the appeal was filed one day late. The Supreme Court ruled that in computing the 15-day appeal period under criminal procedure law, the first day (judgment date) is excluded and the last day included, following American legal principles and Civil Code provisions. This decision harmonized time computation rules across Philippine legal codes and established that appellants must receive fifteen complete 24-hour days to file appeals. The ruling has enduring significance for procedural law in Philippine courts.