Arambulo vs. Laqui

The filing of a complaint for preliminary investigation interrupts the prescriptive period of a crime, and the period remains tolled until the proceedings are terminated without the accused being convicted or acquitted, even if the information was erroneously filed before a court lacking jurisdiction. The Court ruled that the prescriptive period for libel was interrupted upon the filing of the complaint with the prosecutor's office and remained suspended despite the information being erroneously filed with the MTC, as such proceedings had not terminated in a manner that would recommence the prescriptive period.

On December 21, 1993, petitioner Sr. Fidelis Arambulo circulated a letter containing allegedly malicious imputations against private respondents Srs. Helen Ojario and Bernadine Juarez. Private respondents filed a joint complaint-affidavit for libel against petitioner before the Office of the City Prosecutor of Quezon City on February 2, 1994, forty-two days after the alleged crime occurred.

• The Alleged Libel: On December 21, 1993, petitioner circulated a letter containing allegedly malicious imputations against private respondents Srs. Helen Ojario and Bernadine Juarez.
• Filing of the Complaint: On February 2, 1994, private respondents filed a joint complaint-affidavit for libel before the Office of the City Prosecutor of Quezon City, interrupting the prescriptive period after forty-two days.
• Erroneous Filing with the MTC: On April 27, 1994, the Assistant City Prosecutor recommended filing an information for libel. On May 18, 1994, the information was filed with the MTC of Quezon City, a court without jurisdiction over libel cases. The MTC conducted trial until the prosecution rested.
• Transfer to the RTC: On November 8, 1996, the MTC realized its lack of jurisdiction and ordered the case forwarded to the RTC. The case was raffled to RTC Branch 215.
• Dismissal and Re-filing: On April 2, 1997, RTC Branch 215 dismissed the case for lack of jurisdiction, requiring the information to be re-filed anew, but ruled the offense had not prescribed. The City Prosecutor re-filed the information on April 27, 1997, and it was raffled to RTC Branch 218.
• Motion to Quash: Petitioner filed a Motion to Quash on the ground of prescription, which RTC Branch 218 denied on October 3, 1997. The Court of Appeals upheld the denial.

• Petitioner argued that the prescriptive period commenced to run again when the Assistant City Prosecutor recommended the filing of the information.
• Petitioner contended that because the information was erroneously filed with the MTC (which lacked jurisdiction), the prescriptive period was not interrupted and continued to run, resulting in the crime having already prescribed when the information was filed with the RTC.
• Petitioner asserted that the ruling in People v. Olarte was inapplicable because the interruption during preliminary investigation was not disputed.
• Petitioner claimed she was denied her constitutional right to a speedy trial.

• Respondents maintained that the filing of the complaint with the prosecutor's office interrupted the prescriptive period and remained tolled pending the termination of the case, notwithstanding the erroneous filing with the MTC.

• Procedural Issues: Whether petitioner was denied her constitutional right to a speedy trial.
• Substantive Issues: Whether the crime of libel had already prescribed considering the information was initially filed with a court lacking jurisdiction.

• Procedural: The Court ruled that petitioner was not denied her right to a speedy trial. The right to a speedy trial is violated only where there is unreasonable, vexatious, and oppressive delay without the fault of the accused. Petitioner contributed to the delay by filing a Motion to Quash, a Motion for Reconsideration, and petitions before the Court of Appeals and the Supreme Court.
• Substantive: The Court held that the crime of libel had not prescribed. The prescriptive period was interrupted when the complaint was filed with the City Prosecutor and remained tolled pending the termination of the case. The filing of the complaint for preliminary investigation represents the initial step of the proceedings against the offender, and the proceedings are terminated only when the court or prosecutor discharges the accused because no prima facie case is shown. Because the prosecutor found a prima facie case, the proceedings did not terminate. Furthermore, the erroneous filing of the information with the MTC did not terminate the proceedings. Applying People v. Olarte, People v. Galano, People v. Enrile, and Reodica v. Court of Appeals, the Court held that filing an information with a court lacking jurisdiction does not cause the prescriptive period to recommence; the period remains tolled until the case is dismissed. The error of the prosecutor and the MTC, caused by confusion over R.A. 7691, should not prejudice the State's right to prosecute or the offended party's right to vindication.

• Interruption of Prescriptive Period by Filing of Complaint for Preliminary Investigation — The filing of a complaint with the municipal trial court or prosecutor's office, even if merely for preliminary examination or investigation, interrupts the prescriptive period of criminal liability, even if the court cannot try the case on the merits. The period commences to run again only when the proceedings terminate without the accused being convicted or acquitted, such as when the accused is discharged because no prima facie case is shown. The Court applied this to hold that the prescriptive period remained tolled because the prosecutor found a prima facie case and the MTC's dismissal for lack of jurisdiction did not constitute a termination of proceedings on the merits.
• Effect of Erroneous Filing with an Incompetent Court on Prescription — The erroneous filing of an information with a court lacking jurisdiction does not cause the prescriptive period to recommence. The proceedings are considered pending until the court dismisses the case for lack of jurisdiction, at which point the prescriptive period commences to run again. The Court applied this to hold that the period remained tolled while the case was with the MTC and recommenced only upon the RTC Branch 215's dismissal, after which the information was promptly re-filed.

• "In the landmark case of People vs. Olarte... the filing of the complaint with the Municipal Court, even if it be merely for purposes of preliminary examination or investigation, should, and does, interrupt the period of prescription of the criminal responsibility, even if the court where the complaint or information is filed can not try the case on the merits."
• "It is unjust to deprive the injured party the right to obtain vindication on account of delays that are not under his control."

• People v. Olarte, 19 SCRA 494 — Controlling precedent. Held that filing a complaint for preliminary investigation interrupts the prescriptive period, even if the court cannot try the case on the merits.
• Francisco v. Court of Appeals, 122 SCRA 538 — Followed. Broadened Olarte by holding that filing a complaint with the fiscal's office also suspends the running of the prescriptive period.
• People v. Galano, 75 SCRA 193 — Applied. Held that the prescriptive period interrupted by the filing of an information with a court lacking jurisdiction recommenced only when that court dismissed the case.
• People v. Enrile, 160 SCRA 700 — Applied by analogy. Held that filing charges before military tribunals without jurisdiction over civilians interrupted the prescriptive period.
• Reodica v. Court of Appeals, 292 SCRA 91 — Followed. Held that filing a complaint with the fiscal's office interrupted the prescriptive period for quasi-offenses and remained tolled pending termination of the case, even if filed with an incompetent court.
• Guerrero v. Court of Appeals, 257 SCRA 703 — Cited for the doctrine that the right to a speedy trial is violated only by unreasonable, vexatious, and oppressive delay without the accused's fault.

• Article 90, Revised Penal Code — Prescribes the period of prescription for crimes, specifically stating that the crime of libel prescribes in one year. Applied to determine the applicable prescriptive period for the crime charged.
• Article 91, Revised Penal Code — Governs the computation of prescription of offenses, stating that the period commences to run from the discovery of the crime and is interrupted by the filing of the complaint or information, and proceeds to run again when proceedings terminate without acquittal or conviction. Applied to determine when the prescriptive period was interrupted and when it recommenced.
• Article 360, Revised Penal Code — Provides that the information for libel should be filed with the Court of First Instance (now RTC). Cited to explain why the MTC lacked jurisdiction over the crime of libel.
• Section 2, Republic Act No. 7691 — Expanded the jurisdiction of MTCs but excluded cases within the exclusive jurisdiction of RTCs. Cited to explain the confusion that led to the erroneous filing with the MTC.

Melo (Chairman), Vitug, Panganiban, and Purisima, JJ.