Title: 10. People v.

Rivera Name of Digester: ALCARAZ

G.R.No. L-38215, Date: December 22, 1933 Ponente: Butte, J.

38216

Subject / Syllabus Topic: STATCON-extrinsic aid (language of the statute)

Petitioner: People of the Philippine Islands Respondent: Faustino Rivera

Doctrine (if applicable): The title may indicate the legislative intent to extend or restrict the scope of the law
and a statute couched in a language of doubtful import will be construed to conform to the legislative intent
as disclosed in its title

Recit Summary: The accused Faustino Rivera was being charged by the crime of Indictment of the Innocent
planned and punished under the Art 363 of the Revised Penal Code. The Provincial Prosecutor filed a case
against Rivera for filing a complaint in writing and executing an oath accusing falsely and without probable
cause Vito and Moreno of the crime of theft.

Facts:
· Rivera signed and swore to a complaint accusing Vito and Moreno the crime of theft.

· According to the information, the items stolen were a white American suit with one eyeglasses
amounting to P20, one buntal hat which costs P3, and two buttons which cost P3 each, with the total
amount of P39.

· After the case was dismissed, Vito and Moreno filed a complaint against Rivera, charging him with
incriminating innocent people which falls under Article 363 of the Revised Penal Code.

· Rivera objected and claimed that the facts alleged did not fall under Article 363 of the Revised Penal
Code, and that the provision under Article 363 of the Codigo Penal does not appear in the Revised Penal
Code.

· There is no offense encompassing accusation or false report.

· Article 363. Incriminating innocent person.- Any person who, by any act not constituting perjury, shall
directly incriminate or impute to an innocent person the commission of a crime, shall be punished by arresto
menor.
Issue/s: Ruling:
Whether or not Rivera can be charged guilty of incriminating No
innocent people under Article 363 of the Revised Penal Code.

Holding:
· The crime Rivera was accused of is not explicitly stated in the Revised Penal Code, although the crime
of indictment of the innocent is included in the Old Penal Code.

· Article 326 of the Old Penal Code talks about punishment for false prosecutions. Article 363 in the
Revised Penal Code, pertains to punishment for any act which may tend directly to cause a false prosecution.

· It is well settled that where the text of a statute is clear, it is improper to resort to a caption or title to
make it obscure.