People v. Lee, Jr., G.R. No.

234618, September 16, 2019

Doctrine: The case revolves around the issue of prescription in criminal liability. Prescription is one of the
modes of totally extinguishing criminal liability. The prescriptive period for violations of special laws, such
as R.A. No. 7877, is governed by Act 3326, and it begins to run from the day of the commission of the
violation of the law or from the discovery thereof, and it is interrupted by the institution of judicial
proceedings for its investigation and punishment.

Ruling: The Supreme Court ruled in favor of the petitioner, the People of the Philippines, and held that the
offense charged against Lee had not yet prescribed. The prescriptive period for violations of special laws,
such as R.A. No. 7877, begins to run from the day of the commission of the violation of the law or from
the discovery thereof, and it is interrupted by the institution of judicial proceedings for its investigation and
punishment. In this case, the filing of the complaint against Lee with the Office of the Ombudsman on April
1, 2014, effectively tolled the running of the period of prescription. Thus, the filing of the Information
before the Sandiganbayan on March 21, 2017, was well within the three-year prescriptive period of R.A.
No. 7877.

The Sandiganbayan's reliance on the case of Jadewell v. Judge Nelson Lidua, Sr., which involved the
prescription period for violation of a city ordinance, was deemed misplaced as it did not apply to violations
of special laws like R.A. No. 7877. Therefore, the Sandiganbayan erred in dismissing the case based on
prescription. The Court also relaxed the requirements on the certification against forum shopping and
verification in the Petition due to the substantive importance of the case. The Petition was granted, and the
Sandiganbayan was ordered to proceed with the trial of Mateo Acuin Lee, Jr.

AN ACT DECLARING SEXUAL HARASSMENT UNLAWFUL IN THE EMPLOYMENT, EDUCATION OR

TRAINING ENVIRONMENT, AND FOR OTHER PURPOSES

Be it enacted by the Senate and House of Representatives of the Philippines in Congress assembled