Below is a consolidated, up-to-June-2025 primer on prescription of the crimes of estafa and falsification of documents under Philippine law. It is organized so you can (1) identify the controlling statute, (2) see how the length of the prescriptive period is derived, (3) know when the clock starts, stops, or is reset, and (4) appreciate the leading Supreme Court rulings that flesh out the rules in practice.

1. Statutory Foundations

Topic	Core Provisions	Key Amendments
Crime of estafa	Art. 315, Revised Penal Code (RPC)	Values/penalties adjusted by R.A. 10951 (2017)
Crime of falsification	Art. 171 (public officer, notary, etc.) and Art. 172 (private individual or user of falsified document), RPC	R.A. 10951 adjusted fines but did not alter penalty classifications
Prescription of crimes	Art. 90 (how long), Art. 91 (how to count), RPC	None—conceptual rules unchanged since 1932
Interruption by complaint	Recognized in People v. Olarte (G.R. L-13027, Feb 28 1966) and consistently applied, e.g., Panaguiton Jr. v. DOJ (G.R. 167571, Nov 25 2008)

2. How long is the prescriptive period?

2.1 The penalty determines the period

Article 90 ties prescription to the maximum penalty prescribed by law (not to the penalty eventually imposed):

Class of penalty (Art. 25, RPC)	Typical imprisonment range	Crime prescribes in …
Reclusión temporal (12 yrs 1 d – 20 yrs)	12y 1d – 20y	20 years
Prisión mayor (6 yrs 1 d – 12 yrs)	6y 1d – 12 yrs	15 years
Prisión correccional (6 mos 1 d – 6 yrs)	6m 1d – 6 yrs	10 years
Arresto mayor (1 mo 1 d – 6 mos)	1m 1d – 6 m	5 years
Light penalties (arresto menor, public censure, fines ≤ P40,000 after R.A. 10951)	≤ 30 days	1 year

Take-away: work out the statutory penalty first; the prescriptive period is automatic.

2.2 Estafa after R.A. 10951

R.A. 10951 re-pegged the amount tiers to inflation. The resulting penalty brackets look like this (rounded to the nearest hundred thousand pesos for recall-friendliness; consult the statute for exact triggers):

Amount defrauded (post-2017)	Statutory penalty	Prescribes in
> ≈ P8.8 million	Prisión mayor max to Reclusión temporal min	20 y
≈ P4.4 M – P8.8 M	Prisión mayor min-med	15 y
≈ P2.2 M – P4.4 M	Prisión correccional max to Prisión mayor min	10 – 15 y (use higher ceiling)
≈ P1.1 M – P2.2 M	Prisión correccional med-max	10 y
≈ P200 k – P1.1 M	Prisión correccional min	10 y
≤ ≈ P200,000	Arresto mayor & fine	5 y (or 1 y if downgraded to light under the statute)

Why the 10 – 15-year overlap? If the bracket straddles the border between a correctional and an afflictive term, courts err on the side of the longer prescriptive period (People v. Castano, G.R. 197309, Oct 1 2014).

2.3 Falsification

Crime	Statutory penalty	Prescribes in
Art. 171 – Public officer, notary, ecclesiastical minister	Prisión mayor & perpetual special disqualification	15 years
Art. 172(1) – Private individual committing acts in Art. 171	Prisión correccional max & fine ≥ P1 M (after R.A. 10951)	10 years
Art. 172(2) – Use of falsified document	Same penalty as the forger (above), but always correctional in practice	10 years
Art. 172(3) – Commercial/private documents	Prisión correccional min-med	10 years

Because none of these reach the reclusión temporal band, their prescriptive periods never exceed 15 years.

3. When does the clock start?

Article 91 sets three triggers, whichever is earliest:

Date of discovery by the offended party,
Date of discovery by the authorities, or
Date of discovery by their agents (e.g., auditors, investigators).

For estafa by misappropriation, jurisprudence adds a wrinkle: the offense is consummated upon demand and unjustified refusal to return, so “discovery” can coincide with the first demand letter (People v. Flores, 88 Phil 560). By contrast, falsification is consummated the moment the document is forged, so discovery tends to be literal—when the fake reaches someone who can recognize it.

Practical effect: An internal audit report, a barangay blotter entry, even a private-complainant affidavit can all mark “discovery” and start prescription.

4. How is the running period interrupted?

Interruption mechanism	Legal basis	Notes
Filing of a complaint, even for preliminary investigation	People v. Olarte doctrine	Applies to barangay, prosecutor, or Ombudsman filings alike.
Absence of the accused from the Philippines	Art. 91, RPC	Time out of territory does not count.
During trial until final judgment	Art. 91	“Final judgment” = conviction or acquittal that becomes final.
Dismissal or quashal without jeopardy	Art. 91, 2nd ¶	Clock resumes as if no filing had been made (People v. Galano, G.R. 73434, Nov 14 1990).

A conditionally dismissed case (e.g., Provisional Dismissal under Sec. 8, Rule 117) keeps the clock stopped for one year for offenses incurring at most 6 years, two years for heavier ones; after that, you add the unused portion of the original prescriptive period (Sec. 8-9, Rule 117; Pantallano v. People, G.R. 182546, Apr 2 2014).

5. Special issues and jurisprudential refinements

Issue	Leading doctrine / case	Gist
Effect of R.A. 10951 on pending or time-barred cases	People v. Danganan, G.R. 227174, Jan 27 2021	Lowered penalties apply retroactively if favorable, but prescription already completed before 2017 remains a bar.
Multiple estafa counts vs. single prescription	Benitez v. CA, G.R. 57818, Apr 16 1985	Each misappropriation dates its own clock; no “continuing crime” unless conspiracy is alleged.
Civil compromise does not stop criminal prescription	Art. 89(6), RPC; People v. Mañalac, G.R. 94773, Oct 7 1991	Settlement or restitution affects civil liability only.
Administrative discovery: COA/NBI audit	People v. Cabrera, G.R. 219221, Apr 10 2019	Audit report receipt by the Office of the Ombudsman = discovery by authorities.
Sandiganbayan jurisdiction and prescription	Alarilla v. Sandiganbayan, G.R. 70679-80, Oct 13 1988	Filing with the Ombudsman interrupts prescription even before case is filed in Sandiganbayan.

6. Checklist for practitioners

Classify the penalty under the current text of Art. 315 or Art. 171/172 (-► afflictive? correctional?).
Match to Art. 90 to get the base prescriptive period.
Identify discovery date—document it early; if you are prosecution, plead it in the Information.
Map all tolling events: complaints, departures, suspensions of proceedings.
Mind R.A. 10951 retroactivity:
- If it lowers the penalty, the shorter prescriptive period now applies, but not so short as to revive a crime already prescribed.
For estafa via misappropriation, preserve demand letters—they often mark discovery and prove consummation.
For falsification, trace the paper trail; each downstream user can be both discoverer and victim.

7. Quick reference timeline (illustrative)

←––––– Prescribed? –––––→
      |<–running–>|<–suspended–>|<–running–>|

Discovery  Filing for     Case  Provisional   Re-filing
(01 Jun 20) Pre-invest’g  pending dismissal   (15 Aug 23)
            (15 Aug 20)          (15 Aug 22)

Estafa: 10-yr limit
• 01 Jun 20 to 15 Aug 20  =  75 days
• 15 Aug 20 to 15 Aug 22  =  suspended
• 15 Aug 22 to 15 Aug 23  = 365 days
Total used = 440 days; balance ≈ 8 yrs 180 d

8. Bottom-line take-aways

Prescription is penalty-driven: know the penalty, you know the clock.
Discovery, not commission, usually triggers counting—vital in “hidden” crimes like estafa and falsification.
A single filing—anywhere—stops time under the Olarte doctrine; delays in elevating the case no longer matter.
R.A. 10951 helps the accused by shortening some clocks, but it cannot breathe life into crimes that were already time-barred before 2017.
Always keep eye on interruptions (complaint, absence, trial) and resumptions (dismissal, return to PH, provisional dismissal limits).

This material is informational and does not substitute for tailored legal advice. If prescription is in play, consult counsel promptly; the timeline can hinge on a single unnoticed date.