CASE 2: People vs Rivera, GR No.

38215- December 22, 1933

KEYWORD/TOPIC

FACTS Rivera was charged with the offense of "inculpation of an innocent" under Article
363 of the Revised Penal Code for falsely accusing Domingo Vito and Felisa
Moreno of theft. Rivera had filed a complaint accusing Vito and Moreno of theft,
which was subsequently dismissed by the justice of the peace due to lack of
evidence. Following this dismissal, Vito and Moreno separately charged Rivera
with the offense of incriminating an innocent person. Rivera raised objections,
asserting that the facts alleged did not fall under the scope of Article 363 of the
Revised Penal Code, which was repeated on appeal to the Court of First Instance.
The demurrers were sustained, and the cases were dismissed, leading to the
Attorney-General's appeal.
ISSUE WON Article 363 of the Revised Penal Code should be construed to include the
crime of false accusation or complaint as penalized under Article 326 of the old
Penal Code.
RULING The court examined Article 363 of the Revised Penal Code, which punishes acts
tending directly to inculpate an innocent person in a crime, and compared it to
Article 326 of the former Penal Code, which dealt with the offense of false
accusation or complaint. While Article 326 punished false prosecutions made
before an administrative or judicial officer, Article 363 penalized acts that tend
directly to cause a false prosecution. The court emphasized the differences in
language between the two articles and highlighted that Article 363 focused on
acts that "tend directly" to inculpate an innocent person, not solely on the
imputation itself.

The court declined to interpret Article 363 to encompass formal criminal

complaints, emphasizing that the title preceding Article 363, "Asechanzas
Inculpatorias," implied acts that tend to lead to false prosecutions such as
planting evidence, rather than the filing of formal complaints. The court stressed
the need for a sensible interpretation of statutes to align with legislative intention
and to avoid unjust or absurd conclusions. Moreover, the absence of a safeguard
in Article 363, akin to the provision in Article 326 requiring court order for
prosecution of the accuser, indicated that expanding Article 363 to administrative
and judicial proceedings might lead to an influx of prosecutions in cases where
defendants were acquitted. Hence, the court concluded that Article 363 should