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    People of The Philippines Vs Lee Case Digest

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    Cheska Almira J. Arellano
    The Sandiganbayan erred in dismissing a case against Mateo Lee Jr, who was charged with sexual harassment, on the grounds that the offense had prescribed. The Supreme Court ruled that filing a complaint with the Office of the Ombudsman effectively tolls the running of the prescriptive period, as there is no distinction between cases under the Revised Penal Code and special laws. In this case, the complaint was filed in 2014 and the information was filed in 2017, which is within the 3-year prescriptive period under the applicable law. Therefore, the dismissal by the Sandiganbayan was reversed.

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    People of The Philippines Vs Lee Case Digest

    Uploaded by

    Cheska Almira J. Arellano
    2K views2 pages
    The Sandiganbayan erred in dismissing a case against Mateo Lee Jr, who was charged with sexual harassment, on the grounds that the offense had prescribed. The Supreme Court ruled that filing a complaint with the Office of the Ombudsman effectively tolls the running of the prescriptive period, as there is no distinction between cases under the Revised Penal Code and special laws. In this case, the complaint was filed in 2014 and the information was filed in 2017, which is within the 3-year prescriptive period under the applicable law. Therefore, the dismissal by the Sandiganbayan was reversed.

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    People of the Philippines vs Lee case digest

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    The Sandiganbayan erred in dismissing a case against Mateo Lee Jr, who was charged with sexual harassment, on the grounds that the offense had prescribed. The Supreme Court ruled that filing a complaint with the Office of the Ombudsman effectively tolls the running of the prescriptive period, as there is no distinction between cases under the Revised Penal Code and special laws. In this case, the complaint was filed in 2014 and the information was filed in 2017, which is within the 3-year prescriptive period under the applicable law. Therefore, the dismissal by the Sandiganbayan was reversed.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    2K views2 pages

    People of The Philippines Vs Lee Case Digest

    Uploaded by

    Cheska Almira J. Arellano
    The Sandiganbayan erred in dismissing a case against Mateo Lee Jr, who was charged with sexual harassment, on the grounds that the offense had prescribed. The Supreme Court ruled that filing a complaint with the Office of the Ombudsman effectively tolls the running of the prescriptive period, as there is no distinction between cases under the Revised Penal Code and special laws. In this case, the complaint was filed in 2014 and the information was filed in 2017, which is within the 3-year prescriptive period under the applicable law. Therefore, the dismissal by the Sandiganbayan was reversed.

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    © All Rights Reserved
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    of 2

    PP vs. Lee Jr., GR no.

    234618

    Facts:

    Accused Mateo Lee Jr., the Deputy Executive Director of the National Council on Disability
    Affairs, was charged with violation of RA no. 7877 before the Sandiganbayan for demanding
    sexual favor from Diane Jane M Paguirigan an Administrative Aide VI in the same office and
    served directly under his supervision. The accused allegedly asked the victim in several
    occasions when they would check in a hotel, sending food and flowers and messaged of
    endearment and continuing to do so after several protest from her which created an
    intimidating, hostile and offensive working environment to Ms. Paguirigan. Thereafter, Lee filed
    a motion for judicial determination of probable cause and prescription extinguishing criminal
    liability with prayer for outright dismissal of the case which drew an opposition from the OSP,
    aggrieved by the denial of his motion by the Sandiganbayan he filed an Entry of appearance and
    motion for reconsideration of the resolution issued by Sandiganbayan which reconsidered and
    set aside its earlier resolution and ordered the dismissal of the case against Lee on the ground
    the offense charged had already prescribed. Subsequently, the OSP filed a MR which was
    denied. Hence the petition.

    Issue:

    Whether or not the Sandiganbayan erred in ordering the dismissal of the case against Lee on
    the ground of prescription.

    Ruling:

    In reversing the CA’s decision, We emphatically ruled that “(t)here is no more distinction
    between cases under the RPC (Revised Penal Code) and those covered by special laws with
    respect to the interruption of the period of prescription” and reiterated that the period of
    prescription is interrupted by the filing of the complaint before the fiscal’s office for purposes of
    preliminary investigation against the accused.

    In the case at bar, it was clear that the filing of the complaint against the respondent with the
    Office of the Ombudsman on April 1, 2014 effectively tolled the running of the period of
    prescription. Thus, the filing of the Information before the Sandiganbayan on March 21, 2017,
    for unlawful acts allegedly committed on February 14, 2013 to March 20, 2014, is well within
    the three (3)-year prescriptive period of R.A. No. 7877. The court a quo’s reliance on the case
    of Jadewell v. Judge Nelson Lidua, Sr., [13] is misplaced. Jadewell presents a different factual
    milieu as the issue involved therein was the prescriptive period for violation of a city ordinance,
    unlike here as well as in the Pangilinan and other above-mentioned related cases, where the
    issue refers to prescription of actions pertaining to violation of a special law. For
    sure, Jadewell did not abandon the doctrine in Pangilinan as the former even acknowledged
    existing jurisprudence which holds that the filing of complaint with the Office of the City
    Prosecutor tolls the running of the prescriptive period.

    As provided in the Revised Rules on Summary Procedure, only the filing of Information tolls the
    prescriptive period where the crime charged is involved in an ordinance.

    There is no distinction between the filing of the Information contemplated in the Rules of
    Criminal Procedure and in the Rules of Summary Procedure. When the representatives of the
    petitioner filed the Complaint before the Provincial Prosecutor of Baguio, the prescription
    period was running. It continued to run until the filing of the Information. They had two months
    to file the Information and institute the judicial proceedings by filing the Information with the
    Municipal Trial Court.

    According to the Department of Justice – National Prosecutors Service Manual for Prosecutors,
    However, for an offense covered by the Rules on Summary Procedure, the period of
    prescription is interrupted only by the filing of the complaint or information in court.

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