Commonwealth v. Vega-Reyes, 131 A.3d 61

Brandy L. Vega-Reyes was charged with welfare fraud under 62 P.S. § 481(a) for receiving benefits from 2008 through July 31, 2010; the complaint (filed Mar. 27, 2013) alleged $20,375 in improper benefits.
Vega-Reyes moved to dismiss charges based on a four-year statute of limitations, arguing offenses before Mar. 27, 2009 were time-barred.
The trial court granted dismissal and barred evidence of pre-Mar. 27, 2009 conduct as prior-bad-act proof for later offenses.
The Commonwealth appealed; the Superior Court initially affirmed in a divided memorandum, then granted en banc review.
Central legal question: whether the four-year limitations period in the Public Welfare Code (62 P.S. § 481(d)) or the later-enacted five-year general limitations period for Public Welfare offenses (42 Pa.C.S. § 5552(b)(4)) governs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicable statute of limitations for welfare-fraud prosecution	Commonwealth: the later-enacted 42 Pa.C.S. § 5552(b)(4) (five years) controls and applies to Public Welfare Code offenses	Vega-Reyes: the specific four-year limit in 62 P.S. § 481(d) controls because specific statutes prevail over general ones	Court held the five-year limitation under 42 Pa.C.S. § 5552(b)(4) applies; reversed trial court dismissal
Admissibility of pre-limitations-period conduct as evidence of continuing fraud	Commonwealth: excluded evidence was part of a continuing course of fraudulent conduct and thus relevant to later offenses	Vega-Reyes: evidence of pre-Mar. 27, 2009 conduct was barred because those acts were time-barred	Court held reversal of dismissal necessarily abrogates the trial court’s exclusion order (pre-2009 evidence not categorically excluded on statute-of-limitations grounds)

Corban Corporation, 957 A.2d 274 (Pa. 2008) (interpreting conflict between specific statute of limitations and later general statutory limitation; used for principles on statute-precedence and legislative intent)