People v. Hon. Cesar R · G.R. L-47646

Petitioner: People
Respondent: Hon. Cesar R. Maravilla
Citation: G.R. No. L-47646
Court: Supreme Court
Division: First Division
Ponente: Cruz, J.
Decided: September 19, 1988

Whether criminal case for unjust vexation has prescribed under Article 91 of the Revised Penal Code

Summary

This criminal case involves the prescription of unjust vexation charges against lawyer Manuel B. Gadon for allegedly grabbing a woman's breast. The municipal court dismissed the case, ruling it had prescribed because 83 days elapsed from the offense to filing the proper complaint. The Supreme Court reversed, holding that the original complaint for acts of lasciviousness effectively interrupted prescription for unjust vexation since both crimes involve molestation and what controls is the factual description, not the legal designation. The Court calculated that prescription ran only 25 days total, well within the 60-day limit. The case was remanded for trial, establishing important precedent on criminal prescription computation and the principle that factual allegations in complaints control over legal designations.

Statutes applied

Revised Penal Code Art. 91

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Unjust Vexation in the Philippines (Art. 287)

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By Intellegal Editorial Board · September 19, 1988

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