Reodica vs.

CA

Facts: On 17 October 1987, Reodica was involved in a vehicular accident wherein the
van she was driving hit the car of Bonsol. Bonsol suffered physical injuries and sustained
damage to his car amounting to P8,000. 3 days after the incident, Bonsol filed a
complaint against Reodica before the Fiscal’s Office.

On 13 January 1988, an information was filed before the RTC charging Reodica
with "Reckless Imprudence Resulting in Damage to Property with Slight Physical Injury"
wherein she was convicted by the trial court.

Reodica avers that the offense of slight physical injuries through reckless
imprudence, being punishable only by arresto menor, is a light offense; as such , it
prescribes in two months. Here, since the information was filed only almost three
months from the date the vehicular collision occurred, thus, the offense had already
prescribed.

Issue: w/n the offense has already prescribed – NO

Ruling: To resolve the issue of whether these quasi offenses have already prescribed, it
is necessary to determine whether the filing of the complaint with the fiscal's
office three days after the incident in question tolled the running of the
prescriptive period.

ART. 91. Computation of prescription of offenses. — The period of prescription

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, and shall commence to run again when
such proceedings terminate without the accused being convicted or acquitted, or
are unjustifiably stopped by any reason not imputable to him.

In Francisco v. Court of Appeals and People v. Cuaresma, it was held that the
filing of the complaint even with the fiscal's office suspends the running of the
statute of limitations. Thus, the prescriptive period for the quasi offenses in question
was interrupted by the filing of the complaint with the fiscal's office three days after the
vehicular mishap and remained tolled pending the termination of this case.