PEOPLE OF THE PHILIPPINES vs.

BAUTISTA
(G.R. No. 168641, April 27, 2007)
Exonerated from Criminal Liability
FACTS:
Clemente Bautista and Leonida Bautista had a row against Felipe Goyena that led to the
latters slight physical injuries complaint against the former. The complaint was filed by Felipe
Goyena (petitioner, for brevity) at the barangay office in Malate, Manila but no settlement was
attained. The recourse of the petitioner was to file the case against Clemente Bautista and
Leonida Bautista (respondents, for brevity) at the Office of the City Prosecutor (OCP, for
brevity). Upon the recommendation of Prosecutor Jessica Junsay-Ong, a Joint Resolution dated
November 8, 1999 was filed against the respondents and was approved thereafter by the City
Prosecutor, it appeared that it failed to calendar such approval as shown in the records.
Nevertheless, the case was filed to the Metropolitan Trial Court (MeTC, for brevity) on June 20,
2000.
The respondents implored that their case be dismissed on the premise that the time the
case was filed the prescription period of 60 days had elapsed from the time crime was committed
to the filing of the case. The MeTC ruled that the offense had not yet prescribed.
Respondents elevated the issue to the RTC via a Petition for Certiorari, but the RTC
denied said petition and concurred with the opinion of the MeTC.
Respondent then filed a Petition for Certiorari with the CA. the CA rendered its Decision
wherein it held that, indeed, the 60-day prescriptive period was interrupted when the offended
party filed a Complaint with the OCP of Manila on August 16, 1999. Nevertheless, the CA
concluded that the offense had prescribed by the time the Information was filed with the MeTC.

ISSUE:
Whether or not the respondents are exonerated from criminal liability based on the
premise that the 60-day prescription period had already elapsed?

RULING:
Yes. The Office of the Prosecutor miserably incurred some delay in filing the case but
such mistake or negligence should not unduly prejudice the interests of the State and the
offended party. As held in People v. Olarte. It is unjust to deprive the injured party of the right to
obtain vindication on account of delays that are not under his control. All that the victim of the
offense may do on his part to initiate the prosecution is to file the requisite complaint.
The Court will not be made as an unwitting tool in the deprivation of the right of the offended
party to vindicate a wrong purportedly inflicted on him by the mere expediency of a prosecutor
not filing the proper information in due time.
The Court will not tolerate the prosecutors apparent lack of a sense of urgency in fulfilling their
mandate. Under the circumstances, the more appropriate course of action should be the filing of
an administrative disciplinary action against the erring public officials.
The SC hereby REVERSED and SET ASIDE the appealed Orders of both courts below and
Criminal Case No. 344030-CR, entitled: "People of the Philippines, Plaintiff, -versus- Clemente
Bautista and Leonida Bautista, Accused," is ordered DISMISSED. Costs de officio (each party
bears his own expenses).