Key legal question
Whether Art. 16 ELG creates a continuing offence or requires separate limitation periods for each deceptive act.
Extracted holding
Art. 16 ELG is not a continuing offence; each deceptive act is complete when benefits are obtained, so limitation runs separately for each act.
Extracted reasoning
The offence protects lawful payment of supplementary benefits and is completed by the first unlawful payment obtained through deception. The duty to report later changes under Art. 24 ELV does not transform the offence into a continuing one or create a guarantor duty.