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PEOPLE OF THE PHILIPPINES, ET AL. vs. ASCENSION P.                                                          OLARTE                                                    G.R. No. L-22465

9/2/2019

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PEOPLE OF THE PHILIPPINES, ET AL. vs.
ASCENSION P.  OLARTE                             
G.R. No. L-22465
​
Facts:
  •  Ascension P. Olarte, respondents , wrote certain letters which were libelous, contemptuous and derogatory to Miss Visitacion M. Meris
  • On January 7, 1956: Visitacion lodged the corresponding charge of libel with the provincial fiscal of Pangasinan
  • and then, February 22, 1956: Visitacion filed complaint for libel with the Justice of the Peace Court of Pozorrubio, Pangasinan
  • July 3, 1956: Case forwarded to the Court of First Instance of Pangasinan
  • Court of First Instance ruling: case dismissed due to expiration of prescriptive period of two years for libel
Issue:
 Was the statute of limitations suspended by the filing of the complaint with the justice of the peace court? 

Held:
Yes. The filing of the complaint in 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 its merits.
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