This case has been cited 1 times or more.
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2001-10-26 |
QUISUMBING, J. |
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| On the sufficiency of the complaint, appellant urges this Court to apply the ruling in People vs. Santos, 101 Phil 798 (1957), that the complaint filed in court, and not the "salaysay" filed with the fiscal, commences the criminal proceedings.[25] But as early as Valdepeñas vs. People, 16 SCRA 871 (1966), this ruling was already modified. We clarified it more recently in People vs. Bugtong, 169 SCRA 797 (1989), and People vs. Tañada, 166 SCRA 360 (1988), and later cases,[26] that the complaint mentioned in Article 344 of the Revised Penal Code does not confer jurisdiction upon the trial court. It is the law that confers jurisdiction. The salaysay or complaint is merely a condition precedent to the exercise by the proper authorities of the power to prosecute the guilty parties.[27] | |||||