People vs Reyes, 212 SCRA 402
Criminal Case Digest:
Digested Cases
Issue: W/N the crime prescribed
Decision: Yes. The criminal action has been extinguished by
prescription. The
title, once registered is a notice to the world. All persons must take
notice.
Considering the lapse of more than 20 years, the crimes charges already
prescribed.
Issue: Does Art. 91 cannot be construed in such manner as to admit
application of the rule on construction.
Decision: No. Although caution should be observed in applying the rule
of
construction in civil cases, the court will not hesitate to do so if the
factual and
legal circumstance so warrant. The application of the rule on
constructive
notice in the construction of Article 92 of the RPC would most certainly
be
favorable to the accused since the prescriptive period of the crime
shall have to
be reckoned with earlier. The criminal offense of falsification of
public
document has already prescribed.
