G.R. No. L-22465 February 28, 1967
PEOPLE OF THE PHILIPPINES and VISITACION M. MERIS, plaintiffs-appellants, vs. ASCENSION P. OLARTE, defendant-appellee.

FACTS

The defendant, Ascension P. Olarte, was charged with libel for writing and sending defamatory letters to the complainant, Visitacion M. Meris, on or about February 24, 1954, and subsequently thereafter. The complainant filed a charge with the provincial fiscal on January 7, 1956, and subsequently filed a complaint for libel with the Justice of the Peace Court of Pozorrubio, Pangasinan, on February 22, 1956. The defendant waived her right to a preliminary investigation, and the case was forwarded to the Court of First Instance of Pangasinan, where an information was filed on July 3, 1956. The defendant moved to quash the information on the ground of prescription, arguing that the two-year prescriptive period for libel had expired before the filing of the information in the Court of First Instance. The trial court granted the motion and dismissed the case. On first appeal (G.R. No. L-13027), the Supreme Court, in a decision promulgated on June 30, 1960, reversed the trial court, ruling that the filing of the complaint with the justice of the peace court interrupted the running of the prescriptive period, and remanded the case for further proceedings. This decision became final and executory. Upon remand, the lower court set the case for hearing. However, on August 26, 1963, the defense filed a new motion to quash based on prescription, invoking the subsequent ruling of the Supreme Court in People vs. Coquia (G.R. No. L-15456, June 29, 1963), which held that to interrupt prescription, the complaint or information must be filed in the proper court that has jurisdiction to try the case on its merits. The lower court, finding the facts of the case at bar practically identical to Coquia, sustained the motion and dismissed the case, opining that the Coquia ruling indicated an abandonment of the 1960 ruling in the first appeal of this same case. The prosecution appealed.

ISSUE

Whether the Supreme Court’s subsequent ruling in People vs. Coquia (1963) warrants the dismissal of the information in the present case on the ground of prescription, notwithstanding the final and executory 1960 ruling in the first appeal of the same case which held that the filing of the complaint with the justice of the peace court interrupted the prescriptive period.

RULING

No. The Supreme Court set aside the appealed order of dismissal and remanded the case for further proceedings. The Court held that its ruling on the first appeal (L-13027) constitutes the “law of the case.” This doctrine means that whatever is once irrevocably established as the controlling legal rule of decision between the same parties in the same case continues to be the law of the case, whether correct on general principles or not, so long as the facts remain the same. A final decision may no longer be disturbed or modified even if later deemed erroneous; subsequent reinterpretations of the law apply prospectively to new cases, not retroactively to an old one finally determined. Therefore, the issue of prescription was foreclosed by the final 1960 ruling. Furthermore, to provide guidance, the Court reexamined the conflicting precedents on prescription and expressly overruled the doctrine in People vs. Coquia and similar cases. The Court established the doctrine that the filing of a complaint in the Municipal Court (or Justice of the Peace Court), even if only for preliminary investigation, interrupts the period of prescription of the criminal responsibility.