Key legal question
Whether the criminal complaint for misappropriation was filed in time.
Extracted holding
Yes. The complaint period starts only when the offense is completed, i.e. when the injured party suffers the relevant substantial disadvantage; in this case that was on the agreed return date, 1994-05-31.
Extracted reasoning
Misappropriation is not a continuing offense. The limitation period cannot begin before completion of the offense. Completion occurs when the victim sustains the legally relevant damage or substantial disadvantage.