Petitioner
People
Respondent
Felipe Abuy
Citation
G.R. No. L-17616
Court
Supreme Court
Division
En Banc
Ponente
Barrera, J.
Decided
May 30, 1962

Whether the prescription period for unjust vexation was interrupted by the filing of a different criminal case (trespass to dwelling) involving the…

Summary

Felipe Abuy was charged with two separate criminal offenses arising from the same February 21, 1959 incident - first trespass to dwelling (dismissed), then unjust vexation. The Supreme Court affirmed the dismissal of the unjust vexation case on grounds of prescription, holding that unjust vexation is a light offense that prescribes in 2 months under the Revised Penal Code. Since more than 6 months elapsed between the commission date and filing of the unjust vexation information, the offense had clearly prescribed. The Court rejected the prosecution's argument that filing the trespass case interrupted the prescription period, ruling that only the proper information corresponding to the specific offense can interrupt its prescriptive period. This case establishes the principle that criminal prescription is offense-specific and cannot be interrupted by filing charges for different crimes, even if committed by the same accused on the same date.

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By Intellegal Editorial Board · May 30, 1962

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