### Facts:
The case centers around Jadewell Parking Systems Corporation, a private parking operator in Baguio City, Philippines, which, under Baguio City Ordinance 003-2000, was authorized to immobilize vehicles parked illegally by clamping their wheels. On two separate incidents in May 2003, respondents Edwin Ang, Benedicto Balajadia, and others forcibly removed the clamps placed on their illegally parked vehicles and failed to pay the corresponding fines and declamping fees. Jadewell, through its General Manager Norma Tan, filed complaints against the respondents for robbery under I.S. Nos. 2003-1996 and 2003-1997. Balajadia also filed a case against Jadewell’s officials for Usurpation of Authority/Grave Coercion under I.S. No. 2003-1935. The City Prosecutor found no probable cause for robbery but filed charges for violation of Section 21 of City Ordinance No. 003-2000.
The Municipal Trial Court of Baguio City, upon motion by the respondents, quashed the charges due to prescription; the decision was upheld by the Regional Trial Court of Baguio City upon petition for certiorari by Jadewell. The decision was based on the grounds that the two-month prescription period for the filing of the informations had already elapsed when the complaints were filed in court but not when they were submitted to the prosecutor.
### Issues:
1. Whether the filing of the complaint with the Office of the City Prosecutor on May 23, 2003, tolled the prescription period of the offense.
2. If the prescriptive period under Act No. 3326, as amended, applies to violations of city ordinances.
3. Whether the legal personality of Jadewell Parking Systems Corporation to assail the Orders was valid.
### Court’s Decision:
The Supreme Court denied the petition, upholding the decisions of the lower courts that dismissed the charges due to prescription. The Court affirmed that for violations of municipal or city ordinances governed by the Rules on Summary Procedure, the prescriptive period is interrupted only by the filing of the information in court. The filing of the complaint with the office of the prosecutor does not toll the prescription period. The Court also clarified that Act No. 3326, as amended, which prescribes a two-month period for the prescription of offenses penalized by municipal ordinances, applies without distinction to city ordinances. Lastly, the Court recognized the procedural capacity of Jadewell to file the petition for certiorari, emphasizing that aggrieved parties have the right to file such petitions.
### Doctrine:
In cases of violations of municipal or city ordinances, the prescriptive period provided under Act No. 3326, as amended, only stops running upon the filing of the information in court, not with the filing of the complaint with the Office of the Prosecutor.
### Class Notes:
– **Prescription of Offense:** The period within which legal action must be taken. In this case, the prescriptive period for violations of city ordinances is two months.
– **Filing of Complaints vs. Informations:** Complaints are initially filed with the Office of the Prosecutor, but only the filing of information in court tolls the prescription period for municipal or city ordinance violations.
– **Municipal vs. City Ordinances:** Act No. 3326, as amended, applies to both municipal and city ordinances without distinction regarding the prescriptive period.
– **Petition for Certiorari:** A legal remedy wherein a court’s decision is reviewed. The Court clarified that aggrieved parties have the standing to file such petitions if they believe there has been a grave abuse of discretion.
### Historical Background:
This case illuminates the procedural nuances in the Philippine legal system regarding the filing of charges for violations of ordinances and the specific timelines that govern such actions. It also reflects the continuous development and interpretation of laws related to the prosecution of minor offenses, especially in the context of local governance and the enforcement of city ordinances.
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