- Petitioner
- People
- Respondent
- Pedro M. Duran, Jr.
- Citation
- G.R. No. L-13334
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Reyes, J.
- Decided
- April 29, 1960
Whether trial court properly dismissed criminal case for serious slander by deed based on jurisdictional grounds and whether government appeal…
Summary
Mayor Pedro M. Duran Jr. was charged with serious slander by deed for allegedly slapping Municipal Councilor Ignacio A. Amarillo during a council meeting. The trial court erroneously dismissed the case, believing Article 360 of the Revised Penal Code required the offended party to file the complaint. The Supreme Court clarified that this requirement only applies to defamation imputing specific crimes listed in Article 344, not to slander by deed that doesn't impute any crime. However, the Court dismissed the government's appeal because it would violate the accused's constitutional protection against double jeopardy, as the trial court had jurisdiction but dismissed on incorrect legal grounds. This case establishes important precedents on the scope of Article 360's complaint requirements and double jeopardy protections in erroneous dismissals.