People v. Rivera G.R. Nos. 38215 & 38216. December 22, 1933

Facts: Rivera signed and swore to a complaint accusing Vito and Moreno the crime of theft. According to the information, the items stolen were a white American suit with one eyeglasses amounting to P30, one buntal hat which costs P3, and to two buttons which cost P3 each, with the total amount of P39. The justice of the peace dismissed the case. After which, Vito and Moreno filed complaints against Rivera, charging him with  incriminating innocent people, which falls under Article 363 of the Revised Penal Code. Rivera objected and claimed that the facts alleged did not fall under Article 363 of the Revised Penal Code, and that, Article 363 of the Codigo Penal does not appear in the Revised Penal Code.  Hence, there is no offense embracing acusacion o denuncia falsa.

Issue: Whether or not Rivera can be charged guilty of incriminating innocent people under Article 363 of the Revised Penal Code

Held: No. Not guilty and inapplicable.

Ratio:  The crime Rivera was accused of is not explicitly stated in the Revised Penal Code, although the crime of indictment of the innocent is included in the Old Penal Code. Article 363 of the Old Penal Code talks about punishment for false prosecutions. In the Revised  Penal Code, Article 363 pertains to punishment for any act which may tend directly to cause a false prosecution. This provision is limited to acts of planting evidence which do not constitute false prosecution but tend directly to cause false prosecutions.

StatCon maxim: The title may indicate the legislative intent to extend or restrict the scope of the law and a statute couched in a language of doubtful import will be construed to conform to the legislative intent as disclosed in its title.