Lopez

Except as provided in Penal Code sections 799 and 800, a prosecution for an offense punishable by imprisonment in the state prison must “be commenced within three years after commission of the offense.” (Pen. Code, § 801.) This general statute of limitations is subject, however, to a discovery provision for specified crimes. Thus, for offenses involving described misconduct in office by a public employee, the statute of limitations “does not commence to run until discovery of [such] an offense.” (Pen. Code, § 803, subd. (c).) In People v. Swinney (1975) 46 Cal.App.3d 332 [ 120 Cal.Rptr. 148 ] (disapproved on another point in People v. Zamora (1976) 18 Cal.3d 538, 564, fn. 26 [ 134 Cal.Rptr. 784 , 557 P.2d 75 ]), construing an earlier version of the limitations statute, we held that the statute starts to run “when the crime is discovered by either the victim or the responsible law enforcement authorities.” ( 46 Cal.App.3d at p. 344 .) One of the central questions in this appeal relates to who is the victim for purposes of the statute of limitations when the crimes involve misappropriation of public funds and perjury for certifying false official payment invoices. We hold…