In a recent decision, the Supreme Court underscored the critical importance of timely legal action. The High Court’s ruling in Corpus Jr. v. People of the Philippines (G.R. 255740, 16 August 2023) not only overturned a conviction but also shed light on the issue of prescription on cases governed by the Rules of Summary Procedure, particularly in cases of slight physical injuries.
Prescription of a crime or offense is the loss or waiver by the State of its right to prosecute an act prohibited and punished by law after the lapse of a certain period prescribed by law.
The case involves Corpus who was convicted of slight physical injuries under Article 263 of the Revised Penal Code. The incident originated from a confrontation between the accused and Hatamosa, during which Castor allegedly punched Hatamosa, resulting in physical injuries.
The prosecution initially recommended charging the accused with serious physical injuries due to a fracture in Hatamosa’s finger, but Corpus was ultimately convicted by the Metropolitan Trial Court of the lesser offense of slight physical injuries. The Regional Trial Court affirmed the conviction.
Corpus appealed his conviction to the Court of Appeals (CA), arguing, among others, that the charge against him had already been prescribed when the information was filed. However, the CA affirmed his conviction, stating that the crime charged was serious physical injuries, not slight physical injuries.
In upholding the conviction, the CA held that since serious physical injuries were prescribed in 15, 10, or five years, depending on the penalty, the filing of the Information was within the prescription period.
Corpus appealed to the Supreme Court and raised whether the CA correctly held that the crime he was convicted of had not yet been prescribed, among others.
The Supreme Court agreed with Corpus, overturning the lower court’s decision. The Court ruled that although the lower courts correctly applied the variance doctrine, finding Corpus guilty of slight physical injuries despite being charged with serious physical injuries, a critical issue emerged concerning prescription.
The Court emphasized that an accused cannot be convicted of a lesser offense if the statute of limitations for that offense had already expired at the time the information was filed. This principle prevents circumvention of the law on prescription by charging the defendant with a more serious offense.
Although Corpus was found guilty of slight physical injuries, his criminal liability had already been extinguished by prescription. The offense was prescribed within two months, and the information against him was filed more than four months after the incident. The Court clarified that in cases governed by the Rules on Summary Procedure, the prescription is tolled only by filing an information in court, not by the commencement of preliminary investigation or the filing of a complaint before investigating agencies.
In discussing the issue of prescription, the Supreme Court acknowledged its previous rulings that support the notion that the mere filing of a complaint before the prosecutor’s office may toll the prescriptive period. However, the Court clarified that for crimes falling under the Rules on Summary Procedure and within the jurisdiction of Metropolitan Manila, filing a complaint or information before the court effectively interrupts the prescriptive period. This clarification was underscored by the Court’s interpretation of relevant provisions in the Revised Rules on Summary Procedure.
As a result, the Supreme Court acquitted Corpus of the crime of slight physical injuries on the grounds of prescription, reversing the decision of the lower courts.
On a final note, the Supreme Court reminded prosecutors to diligently discharge their functions by keeping in mind the prescriptive period of the crimes in the complaints lodged before them and, on the basis thereof, timely file the necessary information before the proper court.
