US v.

Serapio
GR L-7557
Facts: The accused was charged with libel, subseue!tl" the accused #illed a de$urrer o#
evide!ce co!te!di!g that si!ce the cri$e o# libel which was !ot i!cluded i! the %e!al &ode
alread" prescribed.

'ssue: (hether or !ot the o##e!se did prescribed.

)eld: The supre$e court did !ot resolved that issue si!ce the accused #ailed to raise the
de#e!ce properl", because de#e!ce o# prescriptio! are !ot raised via de$urrer a!d what was !ot
properl" raised was dee$ed waived.
't is !oteworth" that the Supre$e &ourt de#i!ed special cri$i!al law as those laws outside the
%e!al &ode which are pe!al i! character.