Cases No.

2,19,31,32,33

2. Inocentes v. People

GR No. 205963-64, July 7, 2016

F: Amando Inocentes, a Branch Manager of GSIS Tarlac Field Office, was charged with violation of
Section 3(e) of RA No. 3019, as amended (Anti Graft and Corrupt Practices Act), before the
Sandiganbayan. On May 10, 2012, The Sandiganbayan issued a resolution finding probable cause and
ordered the issuance of a warrant of arrest against Inocentes. He immediately posted Bail to avoid
incarceration. Thereafter, Inocentes filed an Omnibus Motion to quash the information alleging that
Sandiganbayan has no jurisdiction, claiming that he has a salary grade below than 27.

I: Whether Sandiganbayan has jurisdiction over a public employee with salary grade less than 27?

H: Yes. It is of no moment that Inocentes does not occupy a position with a salary grade of 27 since he
was the branch manager of the GSIS' field office in Tarlac City, a government-owned or -controlled
corporation, at the time of the commission of the offense, which position falls within the coverage of the
Sandiganbayan's jurisdiction.

19. Justado vs. People

G.R. No. 219567, February 1, 2017

F: Belen filed a complaint, dated March 29, 2010, for grave threats against her brother Justado alleging
that on February 22, 2010, she intervened between the quarrel of her siblings Rosa and Justado when
the latter pointed a gun at her forehead. The Office of the City Prosecutor (OCP) found probable cause
for other light threats instead of grave threats and on September 22, 2010, filed an Information before
the MeTC. The MeTC convicted Justado of Other Light Threats.

On appeal to the SC, Justado claimed that the offense had already prescribed on the basis of Section 11
of the Rules on Summary Procedure and Section 20 of the DOJ Manual. He argued that the Information
should have been filed before the court within two months from February 22, 2010, or the date the
incident occurred, the crime of Other Light Threats being a light offense with a prescriptive period of 2
months. The Information, however, was only filed on September 22, 2010 or 7 months from the date of
the incident. He asserted that the prescription for the offense was not tolled with the filing of the
complaint with the OCP on March 29, 2010.

I: Whether the offense has already prescribed?

R: Yes. The filing of the complaint before the OCP stalled the running of the prescriptive period of the
offense. Article 91 of the RPC is clear and categorical that the prescriptive period is interrupted by the
filing of the complaint or information. The Rules on Summary Procedure cannot supplant what is
provided under the RPC regarding the prescription of offenses. However, in Reodica vs. CA, the Court
explained that the RPC did not distinguish whether the complaint or information was filed for
preliminary investigation or for an action on the merits.
31. Supreme Transportation Liner v. San Andres

GR No. 200444, Aug 15, 2018

F: San Andres the owner of Mabel Tours Bus whose driver sideswiped a Toyota Revo and upon
immediately swerving left hit head-on Supreme Bus. San Andres filed a complaint for damages against
the petitioner which was answered with a counterclaim. The respondent filed a criminal complaint
against the driver of Mabel which the driver admitted and was convicted. However, the civil claim was
not reserved which resulted for RTC and CA to dismiss the respondent’s complaint and the petitioner’s
counterclaim. According to the courts to allow the latter will tantamount to double recovery of
damages.

I: Whether the petitioner’s counterclaim will prosper?

R: Yes. The RTC and CA erred in denying the counterclaim. The Civil actions based on Articles 32, 33, 34
and 2176 of the Civil Code are separate, distinct and independent of the civil action deemed instituted in
the criminal action. Thus, the failure to reserve is not a waiver to file separate and independent civil
actions. Such can be seen in the latest iteration of Rule III of the Revised Rules of Criminal Procedure.

32. People v Lipata

G.R. No. 200302, April 20, 2016

F: The RTC found appellant Gerry Lipata guilty beyond reasonable doubt of the crime of Murder and
sentenced him to suffer the penalty of reclusion perpetua. The RTC also ordered appellant to pay
damages to the heirs of Rolando Cueno. The CA affirmed the Decision of the RTC. However, prior to the
rendition of judgment in the CA, the accused died.

I: Whether the heirs of Cueno can recover damages

R: No. In 1994, this Court, in People v. Bayotas, reconciled the differing doctrines on the issue of
whether the death of the accused pending appeal of his conviction extinguishes his civil liability. The
Court concluded that upon death of the accused pending appeal of his conviction, the criminal action is
extinguished inasmuch as there is no longer a defendant to stand as the accused; the civil action
instituted therein for recovery of civil liability ex delicto is ipso facto extinguished, grounded as it is on
the criminal. However, they may file a separate civil action.

33. Domingo v. Sps. Singson

G.R. No. 203287, Apr 5, 2017

F: The spouses Domingo died leaving as heirs their children Engracia Singson (respondent), Renato
Domingo and his co-heirs whom he represents (the petitioners).

Engracia filed an ejectment suit in Metropolitan Trial Court of Manila against her co-heirs claiming that
she owned the property left by their parents having bought the same. The petitioners contended that
they learned of the sale only when they were served with summons. Consequently, the petitioners filed
complaint with the RTC of Pasig City (Civil Case No. 70898) seeking to nullify the deed of sale on the
ground that their parents' signatures were forged. They also filed a criminal case for falsification of
public document, estafa and use of falsified document in the Office of the City Prosecutor of Pasig City
docketed as Criminal Case No. 137867.

Then, Spouses Singson filed a Motion to Suspend Proceedings Due to Prejudicial Question with the RTC
in Criminal Case No. 137867. They alleged that the validity and genuineness of the Absolute Deed of
Sale, which is the subject of Civil Case No. 70898 then still pending with the RTC Branch 160, are
determinative of their guilt of the crime charged. The RTC granted the suspension

I: Whether the proceedings of criminal cases were properly suspended on the ground of prejudicial
question?

R: Yes. The RTC Branch 264 correctly suspended the proceedings in Criminal Case No. 137867 on the
ground of prejudicial question since, at the time the proceedings in the criminal case were suspended,
Civil Case No. 70898 was still pending. The resolution of the main issue in Civil Case No. 70898 would
necessarily be determinative of the guilt or innocence of the Spouses Singson.