Crim 1 Case Digest - Corpin - CRL1 - JDNT-1B1

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CRIMINAL 1 JERAMIE CORPIN

PROSECUTOR NOJARA LLB-WSP


CASE DIGEST

Inmates of the New Bilibid Prison v. Sec De Lima, et. al


G.R. No. 212719, June 25, 2019

RULING:

In the decision, the SC took note of the definition of “penal laws” to be: “Penal laws and
laws which, while not penal in nature, have provisions defining offenses and prescribing
penalties for their violation.”

Thus the SC in granting the petition and declaring the IRR invalid in so far as it provides
for the prospective application of the grant of GCTA, TASTM, and STAL, stated in the decision:

“While R.A. No. 10592 does not define a crime/offense or provide/prescribe a penalty as
it addresses the rehabilitation component of our correctional system, its provisions have the
purpose and effect of diminishing the punishment attached to the crime. The further reduction of
the length of the penalty of imprisonment is, in the ultimate analysis, beneficial to the detention
and convicted prisoners alike; hence, calls for the application of Article 22 of the RPC.

“The prospective application of the beneficial provisions of R.A. No. 10592 actually
works to the disadvantage of petitioners and those who are similarly situated. It precludes the
decrease in the penalty attached to their respective crimes and lengthens their prison stay; thus,
making more onerous the punishment for the crimes committed. Depriving them of time off to
which they are justly entitled as a practical matter results in extending their sentence and
increasing their punishment. Evidently, this transgresses the clear mandate of Article 22 of the
RPC.”

Lacson v. The Executive Secretary


361 Phil. 251 (1999)

RULING:

There is nothing ex-post facto in R.A. 8249 – an ex post facto law generally provides for a
retroactive effect on penal laws. However, the Court explains, R.A. 8249 is not a penal law. As
the Court defines, ‘Penal laws are those acts of the legislature which prohibit certain acts and
establish penalties thereof; or those that defines crimes, treat of their nature, and provide for their
punishment’. Republic Act 8249 is a substantive law on jurisdiction which is not penal in
character, thus, may not be considered an ex post facto law. Therefore, the argument of the
petitioner that the law in question has retroactive effect and may affect his right to due process
is wrong.

Juarez v. Court of Appeals


G.R. No. 93474, October 7, 1992

RULING:

The petitioner’s contention that BP 877 is an ex post facto law must also be rejected. It is
not penal in nature and the mere fact that it contains penal provisions does not make it so. At any
rate, she is not being prosecuted under the said penal provisions. She was sued in the municipal
court in a civil complaint to eject her from the lot on the ground that she had unlawfully
subleased it.

Lent v. Tullet Prebbon


G.R. No. 189158, January 11, 2017

RULING:

The Court ruled that there is no provision in the Corporation Code using similarly
emphatic language that evinces a categorical legislative intent to treat as a criminal offense each
and every violation of the law. The Corporation Code was intended as a regulatory measure, not
primarily as a penal statute. Sections 31 to 34 in particular were intended to impose exacting
standards of fidelity on corporate officers and directors but without unduly impeding them in the
discharge of their work with concerns of litigation. Thus, there is no compelling reason for the
Court to construe Section 144 as similarly employing the term “penalized” or “penalty” solely in
terms of criminal liability. Further, no legislative intent to criminalize Section 31 and 34 was
manifested in the deliberations on the Corporation Code. The Corporation Code was intended as
a regulatory measure, not primarily as a penal statute. The Court stressed that had the Legislature
intended to attach penal sanctions to Section 31 and 34 of the Corporation Code, it could have
expressly stated such intent in the same manner that it did for Section 74 of the same Code.
Villareal v. People
G.R. No. 151258, February 1, 2012

RULING:

Yes. First, the Court in resolving this issue ruled that the RTC Branch 130 had no
jurisdiction to act on the probation applications of Tecson et. al. for the law requires that an
application for probation be filed with the trial court that convicted and sentenced the defendant,
meaning the court of origin (Branch 121). Hence, its grant of probation with Tecson et. al. is
void.
However, the Court abandoning its previous stance on ineligibility of those who have
appealed their conviction to probation, citing the then recent case of Colinares vs. People that the
Probation Law never intended to deny an accused his right to probation through no fault of his.
Had the RTC done what was right and imposed the correct penalty, he would have had the right
to apply for probation. Moreover, the Court was quick to clarify that it remains that those who
will appeal from judgments of conviction, when they have the option to try for probation, forfeit
their right to apply for that privilege.

Samahan ng mga Progresibong Kabataan v. Quezon City, et al.


G.R. No. 225442, August 8, 2017

RULING:

The court in such issue rejects petitioners' invocation of the overbreadth doctrine,
considering that petitioners have not claimed any transgression of their rights to free speech or
any inhibition of speech-related conduct. The application of the overbreadth doctrine is limited to
a facial kind of challenge and, owing to the given rationale of a facial challenge, applicable only
to free speech cases.

The Court upheld the constitutionality of the Ordinance issued by Quezon City only.
However, it emphasized that the restrictions set by the Curfew Ordinances that apply solely to
minors are constitutionally permissible. The Court recognizes that minors do possess and enjoy
constitutional rights but the exercise of these rights is not co-extensive as those of adults. They
are always subject to the authority or custody of another. As parens patriae, the State regulates
and, to a certain extent, restricts the minors’ exercise of their rights. These limitations
demonstrate that the State has broader authority over the minors’ activities than over similar
actions of adults, and overall, reflect the State’s general interest in the well-being of minors.
Jurisprudence shows that although children generally are protected by the same constitutional
guarantees against governmental deprivations as are adults, the State is entitled to adjust its legal
system to account for children’s vulnerability. The Court’s rulings are grounded on the
recognition that during the formative years of childhood and adolescence, minors often lack the
experience, perspective, and judgment to recognize and avoid choices that could be detrimental
to them. The Court ruled that children’s welfare and the State’s mandate to protect and care for
them as parens patriae constitute compelling interests to justify regulations by the State.

In this case, respondents have sufficiently established that the ultimate objective of the
Curfew Ordinances is to keep unsupervised minors during the late hours of night time off of
public areas, so as to reduce, if not totally eliminate their exposure to potential harm and to
insulate them against criminal pressure and influences which may even include themselves.

People v. Santiago
G.R. No. 17584, March 8, 1922

RULING:

The Court ruled that Act No. 2886 is valid and constitutional. The Act is attacked on
account of the amendments that it introduces in General Orders No. 58, the defense arguing that
the Philippine Legislature was, and is, not authorized to amend General Orders No. 58. However,
the amendments repeatedly made by the Philippine Commission as well as by the present
Legislature are perfectly within the scope of the power of the said legislative bodies as the
successors of the Military Government that promulgated General Orders No. 58.

The provisions of the General Order have the character of statutory law and the power of
the Legislature to amend it is self-evident, even if the question is considered only on principle.
The Philippine Legislature which amended such General Orders is the legal successor of the
Military Government as the legislative body. The Philippine Legislature has then the power, not
inconsistent with the act, by due enactment to amend, alter, modify or repeal any law, civil or
criminal continued in force by an act as it may from time to time see fit. It is also held that
provisions of General Orders No. 58 do not partake of the same character as the provisions of the
constitution, thereby having Act No. 2886 valid and is not violative of any constitutional
provisions and that the same shall have full force and effect.

People v. Siton
G.R. No. 169364, September 18, 2009

RULING:

The Court ruled that the trial court’s decision declaring Article 202 par. 2 of the Revised
Penal Code unconstitutional is reversed and set aside. The Court agrees with petitioner’s claims.
Article 202 is not unconstitutional because it is not vague and overboard as claimed by the
respondents. This is for the reason that the power to define crimes and prescribe their
corresponding penalties is legislative in nature and inherent in the sovereign power of the state to
maintain social order as an aspect of police power. In fact, the municipal trial court also declared
that the law on vagrancy was enacted pursuant to the state’s police power and justified by the
latin maxim “salus populi est supreme lex” and further held that the law on vagrancy was
enacted pursuant to the police power of the state.

Corpuz v. People
G.R. No. 180016, April 29, 2014

RULING:

The Court denied the petition and affirmed the Court of Appeal’s Decision with
modification that the penalty imposed is the indeterminate penalty of imprisonment ranging from
3 years, 2 months and 11 days of prision correccional, as minimum, to 15 years of reclusion
temporal as maximum.

The Court discussed that there seems to be a perceived injustice brought about by the
range of penalties that the courts continue to impose on crimes against property committed
today. However, the Court cannot modify the said range of penalties because that would
constitute judicial legislation. However, Article 5 of the Revised Penal Code provides the
remedy whereby the Court is tasked to report to the Chief Executive, with recommendation for
an amendment or modification of the legal provisions which it believes to be harsh. Thus, the
said provision is based under the legal maxim “nullum crimen, nulla poena sine lege.” Thus, in
this case, the Court gave Congress a chance to perform its primordial duty of lawmaking and
therefore, pursuant to Article 5 of the Revised Penal Code, the Court’s Decision was furnished to
the President, through the Department of Justice.

People v. Amigo
G.R. No. 116719, January 18, 1996

RULING:

The Supreme Court hold that Article III, Section 19 (1) does not change the penalty
periods prescribed by Article 248 of the Revised Penal Code except only in so far as it prohibits
the imposition of death penalty. The range of the medium and minimum penalties remain the
same.

The Court reversed the doctrine providing for three new periods for the penalty of murder
as reduced by the Constitution. It returned to its original interpretation and held that Article III,
Section 19 (1) of the Constitution does not change the periods of penalty prescribed by Art. 248
of the Revised Penal Code except only insofar as it prohibits the imposition of the death penalty
and reduced it to reclusion perpertua. The Court affirmed the decision and held that courts are
not the forum to plead for sympathy as the duty of the courts is to apply the law, disregarding
their feeling of sympathy or pity for an accused, as enunciated by the maxim dura lex sed lex.
David v. Macapagal-Arroyo
G.R. Nos. 171396, 171409, 171485, 171483, 171400, 171489, and 171424, May 3, 2006

RULING:

The Court ruled that the provisions of PP 1017 commanding the AFP to enforce laws not
related to lawless violence are unconstitutional. Further, the warrantless arrest and whimsical
seizure, in the absence of proof that the petitioners were committing acts constituting lawless
violence, invasion, or rebellion are declared unconstitutional. The Court explained that PP 1017
is merely an invocation of the President’s calling-out power. Its general purpose is to command
the AFP to suppress all forms of lawless violence, invasion or rebellion. However, there is
nothing in PP 1017 that allows the police, expressly or impliedly, to conduct illegal arrest, search
or violate the citizens’ constitutional rights. Thus, the Court held that the military and police
committed acts which violate the citizens’ rights under the Constitution and declared such acts
unconstitutional and illegal.

Dissenting Opinion, Justice Carpio: Romualdez v. People, COMELEC, et al.


G.R. No. 167011, April 30, 2008

RULING:

Justice Carpio ruled said Section 45 (j) unconstitutional. The same makes violation of any
of the provisions of RA 8189 a criminal offense. There are many more provisions of said law
that may be violated by a voter, Election Officer, or other officials of the COMELEC without
committing the Election offenses specified in Section 45 (a) to (i) of RA 8189. However, the
ordinary citizen has no way of knowing which provisions of the law are covered by Section 45
(j) even if he has before him a copy of the law. Under the same, law enforcement officers have
wife latitude to choose which provisions of the law to consider a crime since there is no specific
enumeration of provisions falling under Section 45 (j). It further does not specify what
provisions of the law, if violated, carry a penal sanction. It merely states that violation of any of
the provisions of the law is a crime. Thus, it fails to satisfy the requirement that for an act to be a
crime, it must clearly, be made a crime by express provision of law.

Garcia v. Judge Drilon et al


G.R. No. 179267, June 25, 2013

RULING:

R.A. 9262 does not violate the guaranty of equal protection of the Constitution. The law
rests on substantial distinction with the fact that women are more likely than men to be victims
of violence. Further, such classification is germane to the purpose of the law which is to address
the violence committed against women and children. The classification is not limited to existing
conditions only as it applies equally to all women and children who suffer violence and abuse.
The Court held that there is nothing in the definition of the law that is vague and ambiguous that
will confuse petitioner in his defense.

The Court likewise ruled that RA 9262 is not violative of the due process clause of the
Constitution. It held that the scope of reliefs in protection orders is broadened to ensure that the
victim or offended party is afforded all the remedies necessary to curtail access by a perpetrator
to the victim.

U.S., et al v. Ruiz
136 SCRA 487 (1987)

RULING:

The Court ruled to grant the petition because the projects were an integral part of the
naval base which is devoted to the defense of both the United States and the Philippines,
indisputably a function of the government of the highest order. Thus, the same were not utilized
for nor dedicated to commercial or business purposes. The contract relates to the exercise of the
country’s sovereign functions.

The traditional rule of State immunity exempts a state from being sued in the courts of
another state without its consent or waiver. This rule is a necessary consequence of the principles
of independence and equality of states. However, the rules of international law are not petrified;
they are constantly developing and evolving. And because the activities of states have multiplied,
it has been necessary to distinguish them — between sovereign and governmental acts and
private, commercial and proprietary acts. The result is that state immunity now extends only to
sovereign and governmental acts.

The restrictive application of state immunity is proper only when the proceedings
arise out of commercial transactions of the foreign sovereign, its commercial activities or
economic affairs. A state may be said to have descended to the level of an individual and can
thus be deemed to have tacitly given its consent to be sued only when it enters into business
contracts. It does not apply where the contract relates the exercise of its sovereign function. In
this case, the projects are an integral part of the naval base which is devoted to the defense of
both the US and the Philippines, indisputably a function of the government of the highest order;
they are not utilized for nor dedicated to commercial or business purposes
Rep. of Indonesia v. Vinzon
G.R. No. 154705, June 26, 2003

By the principle of the sovereign equality of States, as expressed in the maxim “par in
parem non habet imperium,” all states are sovereign equals and cannot assert jurisdiction over
one another, for a contrary attitude would unduly vex the peace of nations. The Court ruled to
grant the petition. It explained that international law is founded largely upon the principles of
reciprocity, comity, independence, and equality of States, which were adopted as part of the law
of our land under Article II, Section 2 of the 1987 Constitution. The Court found no waiver of
submission by the petitioner. It held that the State may enter into contracts with private entities to
maintain the premises, furnishings, and equipment of the embassy and the living quarters of its
agents and officials. Thus, the petitioner Republic of Indonesia was acting in pursuit of a
sovereign activity when it entered into a contract with respondent for upkeep or maintenance of
the air conditioning units, generator acts, electrical facilities, water hearters, and water motor
pumps of the Indonesian Embassy and the official residence of the Indonesian ambassador. The
Court submits that the maintenance agreement was entered into by the Republic of Indonesia in
the discharge of its governmental functions.

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