THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs.

JUAN MORAN, FRUCTUOSO CANSINO, and HILARIO ODA, defendants- appellants.

[G.R. No. 17905. January 27, 1923.]

ARAULLO, C.J

Facts:

On December 20, 1920 an action was filed against defendants Juan Moran, Fructuoso Cansino, and
Hilario Oda, election inspectors of the first precinct of the municipality of Binalonan, Pangasinan, for
having falsified election returns. The defendants and were later found guilty by Judge of First Instance
Nepomuceno and again on appeal by the Supreme Court for a crime punishable under Chapter 18 of the
Administrative Code or the Election Law.

On March 9, 1922, Act No. 3030 amending certain provision of the Election Law and providing for a
prescriptive period for acts done in violation of said code was enacted by the Legislation. Section 71 of
Act No. 3030 says: "Offenses resulting from violations of this Act shall prescribed one year after their
commission,"

On May 2, 1922, the defendants filed a motion for reconsideration in the Supreme Court alleging that the
crime complained of had prescribed under the new provisions of section 71 of Act No. 3030. Defendants
pray that they be absolved from the complaint and from the related penalties thereof.

Issue:

Whether or not the prescriptive provision of Act No. 3030 be given retrospective effect for offenses
committed done before its effectivity, in accordance with Art. 22 of the Penal Code?

Held:

Art. 22 of the Penal Code states Penal laws shall have a retroactive effect in so far as they favor the
person guilty of a felony.. In the case at bar, defendants were charged with violating the Election Law on
December 20, 1920. On March 9, 1922, Legislation passed an Act amending the Election Law and
providing for a one-year prescriptive period for offenses resulting from violations of the said act.

The SC maintained that said article 22 of the Penal Code refers NOT only to penalties but also to appeals
and proceedings, because the prescription of the crime is intimately connected with that of the penalty. It
also held that the prescriptive provision of Act No. 3030 must have retroactive effect, the same being
favorable to the accused. It stated the sovereign, in enacting a subsequent penal law more favorable to
the accused, has recognized that the greater severity of the former law is unjust. The sovereign would be
inconsistent if it would still enforce its right under conditions of the former law, which has already been
regarded by conscientious public opinion as juridically burdensome.

The SC ruled in favor of the defendant and dismissed the case for having already prescribed.