Key legal question
Whether the complainant had standing to appeal the dismissal of a private-complaint offence case.
Extracted holding
Yes. As injured person acting as private prosecutor in a complaint-only offence, he could appeal the dismissal.
Extracted reasoning
For offences prosecuted only upon complaint, the public prosecutor does not prosecute; the injured complainant acts as private prosecutor and has standing under Art. 81(1)(b)(4) LTF.