PEOPLE VS OLARTE

Law of the Case

Issue: Can the case be dismissed on the grounds of prescription of the offense, as ruled
in People vs. Coquia?

Facts:
- On February 24, 1954, Meris received a libelous letter from Olarte
- On February 22, 1956, Meris filed a complaint for libel against Olarte with the
Justice of the Peace Court
- The Justice of the Peace Court then forwarded the case to the Court of First
Instance of Pangasinan where Meris filed an information on July 3, 1956
- Olarte moved to quash the information upon the ground of prescription of the
offense, which the Court of the First Instance of Pangasinan granted
- Meris appealed to the Supreme Court, which ruled that the offense had not yet
expired on the grounds of prescription, as it was interrupted by the filing of a
complaint at the Justice of the Peace Court
- The Court of First Instance of Pangasinan set the case for hearing, where Olarte
moved to quash the information on the ground of prescription of the offense,
now referencing to People vs Coquia as a precedent. The Court granted the
motion.
- Meris once again appealed to the Supreme Court on a question of law

Held: No, the case cannot be dismissed on the grounds of prescription of the offense, as
ruled in People vs. Coquia

Ratio:
- “Law of the case” means that whatever is once irrevocably established as the
controlling legal rule of decision between the same parties in the same continues
to be the law of the case, whether correct or not, as long as the facts of the case
stayed the same
- On Law of the Case. The Supreme Court had already previously decided on the
case of Meris and Olarte, in which the Court decided that the offense had not yet
expired. Despite the same Court ruling in the opposite way in another case with
identical facts, the decision of the Court in the first appeal still stands.