G.R. No. L-4975, THE UNITED STATES, plaintiff-appellee, vs. SANTIAGO NARVAS, defendant-appellant., November 9, 1909

FACTS:
The Code of Criminal Procedure outlines two methods for instituting criminal actions: by a sworn written complaint from any person or by an information presented and signed by the promotor fiscal. However, Act No. 1773 , Section 1, mandates that certain crimes, including estupro (seduction), when committed against persons who are not public officials or employees, shall only be prosecuted upon the complaint of the aggrieved party or their parents, grandparents, or guardian.

In the present case, defendant-appellant Santiago Narvas, a private individual, was charged with the crime of estupro. The prosecution was initiated solely upon an information filed by the fiscal, and no complaint was made by the aggrieved person. The lower court proceeded with the trial and convicted Narvas.

ISSUE:
Did the lower court acquire jurisdiction over the person of the defendant and the subject-matter of the action when the crime of estupro, committed against a private individual, was prosecuted through an information filed by the fiscal without the required complaint from the aggrieved party?

RULING:
No. The Supreme Court ruled that for crimes enumerated in Act No. 1773 , Section 1 (such as estupro against a private person), the action cannot be prosecuted upon the information of the fiscal alone. To confer jurisdiction over the person of the defendant and the subject-matter of the action, it is indispensable that the complaint be made and executed in writing by the offended party personally, or by one of the specified relatives, as stipulated by law.

Since no such complaint was made by the aggrieved person in this case, the lower court did not acquire jurisdiction. Consequently, the judgment of the lower court convicting Santiago Narvas was reversed, the information dismissed, and the defendant ordered discharged from custody.