G.R. No.

L-22465
People of the Philippines, et al., plaintiffs-appellants v. Ascencion P. Olarte, defendant-
appellee

FACTS:
On February 24, 1954, Visitacion Meris received a libelous letter from Olarte. Subsequently,
Meris lodged the charge of libel with the provincial fiscal of Pangasinan on January 7, 1956. She
then filed a complaint for libel with the Justice of Peace Court against Olarte on February 22,
1956.

Justice Peace Court forwarded the case to the Court of First Instance of Pangasinan where a
corresponding information was filed on July 3, 1956. Olarte moved to quash the information on
the ground of prescription of the offense.

The CFI granted the motion to quash the information and dismissed the case.

Meris then appealed to the SC. According to the said Court, it is provided in Article 90 of the
Revised Penal Code that “the crime of libel… shall prescribe in two years”, and pursuant to
Article 91 of the same Code, “shall commence to run from the day on which the crime is
discovered by the offended party, the authorities or their agents and shall be interrupted by
the filing of the complaint or information.” According to Meris, she had received defamatory
letters on February 27, March 1 & 3, April 26 and May 9 in the year 1954. The trial judge held
that the prescriptive period had expired before the filing of the information.

The SC rendered a decision on June 20, 1960 reversing the decision of the trial court. The SC
stated that the filing of the complaint in the Justice of the Peace Court interrupted the running
of the statute of limitations and said crime of libel had not been extinguished.

However, the defense presented a new motion to quash the information and another motion on
the ground of prescription of the offense charged in the information.

The defense invoked the subsequent ruling of the SC in the case of People v. Coquia (L-15456)
promulgated on June 29, 1963. The lower court sustained the defense’s new motion to quash
upon the ground of prescription. The ruling in the Coquia case indicated that the SC intended to
abandon the ruling made in the case of Olarte on the first appeal.

Olarte presented a motion to dismiss the appeal but the SC denied said motion. Upon moving to
have the motion reconsidered, the SC overruled the defendant’s motion.

ISSUE:
Whether the decision in the subsequent case of People v. Coquia warrants the dismissal of the
information in the case at bar on the ground of prescription.
DECISION:
The appealed order of dismissal is set aside and reversed with the records of the case remanded
to the lower court for further proceedings conformably with this decision.

REASONING:
No. The ruling of the SC in the first appeal of People v. Olarte, constitutes the law of the case and
even if it is erroneous, it may no longer be disturbed or modified since it became final. A
subsequent reinterpretation of the law may be applied to new cases but not to a case that has
been finally determined.

As said in the prior case of People v. Pinuila

'Law of the case' has been defined as the opinion delivered on a former appeal.
More specifically, it 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 on which such decision was predicated continue to be the facts
of the case before the court.

Subsequent changes in the doctrine of the SC cannot retroactively be applied to nullify a prior
final ruling in the same proceeding where the prior decision was done whether the case is civil or
criminal in nature.

A series of precedents hold that the filing of the complaint with the justice of peace court does
interrupt the course of the prescriptive term. Meanwhile, there are also decisions where the
complaint or information must have been filed in the proper court of jurisdiction to produce the
interruption of the prescriptive term.

As such, the court holds that the filing of the complaint in the Municipal Court or Justice of Peace
Court should, and does interrupt the period of prescription even though the complaint or
information cannot be tried on its merits.

Moreover, it is also unjust to deprive the injured party of the right to obtain vindication on
account of delays which are not under his control.