Prisoners or the Nelson Mandela Rules, which provide
TITLE X that “purposes of a sentence of imprisonment or similar
CRIMES AGAINST PROPERTY measures deprivative of a person’s liberty are primarily to
CHAPTER III – THEFT protect society against crime and to reduce recidivism.
Those purposes can be achieved only if the period of
imprisonment is used to ensure, so far as possible, the
People of the Philippines vs. Ruby Agustin and Jovelyn reintegration of such persons into society upon release so
Antonio | G.R. No. 223107, March 15, 2023 that they can lead a law-abiding and self-supporting
life.” The Court thus ordered Jovelyn’s immediate release,
Doctrine: Imprisonment beyond the maximum penalty is unless she is being lawfully held for another cause.
not only cruel and inhumane but also undermines the
dignity of detainees.
Facts: In 2011, the Regional Trial Court (RTC) convicted BOOK I
Jovelyn of qualified theft for unlawfully taking money from TITLE 1
her employer, GQ Pawnshop. As the secretary, Jovelyn was CHAPTER II
responsible for verifying the authenticity of pawned items. JUSTIFYING CIRCUMSTANCES AND
She used individuals to pawn fake items, ultimately leading CIRCUMSTANCES WHICH EXEMPT FROM
to the release of a total of PHP 585,250 in appraised value CRIMINAL LIABILITY
to the pawners.
Mare Claire Ruiz* vs. People of the Philippines | G.R.
Jovelyn was sentenced to reclusion perpetua, or at least 30 No. 244692, October 09, 2024
years in prison, and was committed to the Correctional
Institution for Women on November 24, 2011. In 2014, the Doctrine: Past Psychiatric Records Not Required to Prove
Court of Appeals affirmed her conviction, prompting the Legal Insanity. Legal insanity only requires evidence that
present appeal before the Supreme Court. the accused was deprived of intelligence either before,
during, or immediately after the crime.
Held: The Supreme Court also upheld her conviction,
finding that the prosecution was able to show all the Facts: The accused was charged with homicide after her
elements of qualified theft. father found her in a disturbing scene – naked, covered in
blood, and chanting religious phrases over her best friend’s
Under Article 308 of the Revised Penal Code (RPC), there lifeless body. She claimed she attacked her best friend after
is theft when one, with intent to gain but without she saw her grow horns and transform into a demon. She
violence, intimidation, or force, takes the personal also reported hearing the Virgin Mary’s voice instructing
property of another without consent. The crime is her to place a cross into the victim’s heart, among other
qualified, increasing the penalty, when committed with commands.
grave abuse of confidence.
Both the Regional Trial Court (RTC) and the Court of
The Court found that Jovelyn took the proceeds from the Appeals found the accused guilty, rejecting her defense of
fake transactions, taking money from her employer and insanity. They ruled that the medical assessment should
abusing the confidence entrusted to her as GQ Pawnshop’s have evaluated her mental state before, during, and after the
secretary. crime. However, since the examinations were conducted
only after the crime, they could not confirm with certainty
However, the Court reconsidered the penalty that could be whether she was fully aware of her actions.
imposed. Given the amount stolen, the penalty for
Jovelyn’s crime is prision mayor, which carries a maximum Held: The SC overturned their rulings and found that the
imprisonment term of up to 10 years and 8 months. accused showed enough evidence of insanity at the time of
the crime. It clarified that proving legal insanity only
Under Article 89, paragraph 2 of the RPC, criminal requires evidence that the accused was deprived of
liability is extinguished by service of the sentence. intelligence either before, during, or immediately after
Jovelyn has been detained since November 24, 2011, or for the crime.
almost 12 years. As the maximum penalty for her crime is
10 years and eight months, she had already been detained Under Article 12 of the Revised Penal Code, a person who
beyond the maximum imposable penalty. committed a crime and was found legally insane is
exempt from criminal liability because they cannot
The Court emphasized that the power of the courts to understand the wrongfulness of their actions. The SC
commit prisoners carries with it the duty to immediately recognized the difficulty of proving insanity at the exact
release them in case of detention for a period equivalent to moment of the crime, so courts may consider the
or longer than the maximum imposable penalty. accused’s behavior before or after the incident.
This is consistent with the principles under the United The SC clarified that while prior medical records can be
Nations Standard Minimum Rules for the Treatment of relevant, they are not required to prove that the
accused’s medical condition led to the crime. Therefore, Rather than serving jail time, the accused will complete
the absence of documented psychiatric history should community service that benefits the area where the
not be taken against the accused claiming legal insanity. crime was committed. Community service involves any
physical activity that fosters civic awareness related to
The SC also acknowledged the unfair burden on enhancing public works or encouraging public service.
impoverished individuals who may not have access to
psychiatric care, emphasizing that legal defenses should The court will decide how many hours he must complete
be equally available to all. To require prior medical and set a timeframe for finishing it. A probation officer
records “puts the impoverished at a disadvantaged position, will oversee the service. If the accused completes the
who, due to circumstances beyond their control, are forced service, the court will release him. If he fails to comply, he
to brush aside conditions of their health in order to will serve his original sentence.
prioritize the immediate need to put food on the table and
other necessities. The plea of insanity, as like any other The SC emphasized that community service is a privilege,
similar defense available under the law, should always be not a right:
equally accessible to all, regardless of background or status. “[T]he imposition of the penalty of community service is
Adding additional burdens and qualifications to avail them, still within the discretion of the court and should not be
when not necessary and decisive to the legal issue, is taken as an unbridled license to commit minor offenses. It
underserving to be branded as a dispensation of justice.” is merely a privilege since the offender cannot choose it
over imprisonment as a matter of right. Further, in requiring
While the accused is exempt from imprisonment, the SC community service, the court shall consider the welfare of
ordered her confinement in the NCMH for full evaluation the society and the reasonable probability that the person
and treatment. She may only be released upon the sentenced shall not violate the law while rendering the
recommendation of her attending physician and approval service.”
from the RTC.
The SC instructed the MeTC to conduct hearings to
REPUBLIC ACT NO. 11362 determine the number of hours the accused must work and
COMMUNITY SERVICE ACT the timeframe in which he is to fulfill the service under the
Teddy Peña vs People of the Philippines | G.R No. supervision of a probation officer assigned by the court.
261807, August 14, 2024
Doctrine: The Community Service Act took effect on CRIMES AGAINST HONOR
August 8, 2019, allowing courts to replace short-term jail CHAPTER I – LIBEL
sentences (ranging from 1 day to 6 months) with OTHER CASES:
community service under terms determined by the court, People of the Philippines vs. XXX262846 | G. R. No.
considering the seriousness of the crime and circumstances 262846, February 18, 2025
of the case.
Doctrine: Courts May Increase Penalties on Appeals Filed
Facts: The accused was convicted in 2016 by the by the Accused
Metropolitan Trial Court (MeTC) and sentenced to 15 days
in jail and PHP 5,000 in moral damages for slight physical Facts: In 2013, the victim, then 16 years old, was sexually
injuries, and 15 days in jail and a PHP 200 fine for unjust violated twice by her father, the accused XXX. During the
vexation. The Regional Trial Court, the Court of Appeals, second incident, the victim kneed XXX in the stomach as
and the SC upheld his conviction. he was about to climb on top of her with his genitals
exposed, forcing him to leave the room.
Meanwhile, the Community Service Act took effect on
August 8, 2019, allowing courts to replace short-term Convicted by both the trial court and the Court of Appeals
jail sentences (ranging from 1 day to 6 months) with of rape for the first incident and unjust vexation for the
community service under terms determined by the second incident, XXX appealed to the SC.
court, considering the seriousness of the crime and
circumstances of the case. While the SC upheld XXX’s conviction for rape, it found
him guilty of attempted rape as regards the second incident,
Similarly, A.M. No. 20-06-14-SC, known as the Guidelines which carries a heavier penalty than unjust vexation.
for the Community Service Act, became effective in
November 2020. The accused then filed a motion for Held: The SC acknowledged that in several earlier
reconsideration, asking the SC to apply this law decisions, it had limited its review of appeals to avoid
retroactively to his sentence. violating the accused’s right against double jeopardy, which
prohibits a person from being prosecuted or punished more
Held: The SC ruled in his favor, stating that penal laws than once for the same offense.
that benefit the accused can be applied retroactively
unless the accused is a habitual offender. In the 2010 case of People vs. Balunsat, the SC said it
could no longer review the Court of Appeals’ decision to
downgrade the conviction from attempted rape to acts of
lasciviousness, as this amounted to an acquittal of the more
serious charge. In this case, the Information expressly stated that the victim
was BBB’s own niece. Although it did not specify the exact
However, in the present case, the SC held that Balunsat was degree of their relationship, it clearly described their
incorrect in invoking the accused's right against double connection in ordinary language. “[A] description that
jeopardy. clearly and categorically identified [the victim] as [BBB’s]
niece satisfies the requirement to inform him fully and
When the accused appeals a conviction, they waive this prepare a defense.”
right and open the entire case for review—including the
possibility of a heavier penalty. In contrast, when it is BBB was sentenced to up to 40 years in prison, without
the State that seeks to challenge an acquittal or request eligibility for parole. He was also ordered to pay PHP
a harsher penalty, the accused may rightfully invoke the 300,000 in damages.
protection against double jeopardy.
TITLE VIII
CRIMES AGAINST PERSONS
CHAPTER III – RAPE
People of the Philipines vs. BBB254878 | G.R. No.
254878, October 22, 2024
Doctrine: Use of Common Family Terms, Such as Niece,
Uncle, in Crime Charge Enough to Inform Accused of
Relation to Victim
Facts: BBB was charged with rape for sexually abusing an
eight-year-old. The Information, or the charge sheet, stated
that the victim was his own niece.
The victim testified that her maternal uncle BBB had
dragged her to a hut, undressed her, and had sexual
intercourse with her three times. After satisfying his lust, he
threatened to kill her parents if she told anyone about the
incident. BBB again sexually violated her three years later.
The Regional Trial Court (RTC) found BBB guilty of
statutory rape and imposed a higher penalty because of his
relationship to the victim.
Under the Revised Penal Code, statutory rape is
committed when a man has sexual intercourse with a
girl below 12 years old,* even without force, threat, or
intimidation. The crime is qualified, i.e. the penalty is
increased, when the offender is “a parent, ascendant,
step-parent, guardian, relative by consanguinity or
affinity within the third civil degree, or the common-law
spouse of the parent of the victim.”
However, the Court of Appeals (CA) ruled that BBB could
only be convicted of statutory rape. It said that the crime
cannot be qualified by relationship because the
Information did not clearly state the degree of
relationship between BBB and the victim, as it did not
use the phrase, “relative within the third civil degree.”
Held: The SC disagreed with the CA and upheld BBB’s
conviction of statutory rape, qualified by relationship.
The SC clarified that using common terms that clearly
define the relationship is sufficient to inform the
accused and uphold fairness and due process.
BOOK I his father, asked for forgiveness, and then cut his own
CIRCUMSTANCES AFFECTING CRIMINAL throat and abdomen.
LIABILITY
MITIGATING CIRCUMSTANCES On his way to a nearby spring afterward, Singcol
People of the Philippines vs. XXX | G.R. No. 261962, encountered his sister-in-law and her two-year-old son. He
January 27, 2025 attempted to stab her but injured the child instead. The
mother lost her grip on the boy, and Singcol fatally stabbed
Doctrine: R. A. No. 11642 (Domestic Administrative her. The child survived.
Adoption and Alternative Child Care Act) which took effect
in 2022, expanded the relationship to include the adopter’s During trial, Singcol admitted to stabbing his father, his
parents, legitimate siblings, and legitimate descendants. sister-in-law, and the child. He said he had suffered abuse
Relationship is a qualifying circumstance. from his father since childhood and was not thinking
clearly when he attacked the others.
The Supreme Court (SC) has ruled that a child’s rape by her
adoptive uncle does not warrant a harsher penalty because Both the Regional Trial Court (RTC) and the Court of
they are not related, based on the prevailing law at the time Appeals convicted Singcol of parricide for killing his
of the crime. However, recent adoption laws enacted father.
after the crime now recognize the relationship between
an adoptee and their adoptive relatives and may qualify Held: While the Supreme Court agreed with them that self-
the crime. defense was not applicable in this case, it ruled that passion
or obfuscation should be considered as a mitigating factor
The SC thus upheld the accused’s conviction but declared or circumstance that lessens the penalty.
him guilty of statutory rape instead of qualified rape. Case
records show that sometime in November 2012, while the Under the Revised Penal Code, parricide is committed
victim was asleep, her adoptive mother’s brother forcibly when the accused kills their parents or child, whether
had sex with her. legitimate or illegitimate, or any of their ascendants or
descendants, or legal spouse.
While the Regional Trial Court and the Court of Appeals On the other hand, passion or obfuscation is a state of
found the accused guilty of qualified rape, considering the mind present when a crime is committed due to an
victim’s minority and the fact that he is a relative by blood uncontrollable burst of emotions triggered by previous
within the third civil degree, the SC disagreed. unjust or improper acts.
The SC clarified that at the time the rape was committed, The SC considered the parricide a result of “a sudden surge
the existing laws on adoption did not consider the victim to of the accused’s bottled-up feelings caused by paternal
be related to her adoptive parents’ family. neglect since childhood,” as shown by Singcol’s narration
and his extreme, irrational acts of self-harm immediately
While R. A. No. 11642, or the Domestic Administrative after the killing.
Adoption and Alternative Child Care Act, which took effect
in 2022, expanded the relationship to include the adopter’s Singcol was sentenced to reclusion perpetua, or a maximum
parents, legitimate siblings, and legitimate descendants, it of 40 years in prison, for the parricide and the murder of his
could not be applied to this case since the crime was sister-in-law, and ordered to pay the heirs of each victim
committed in 2012. PHP 275,000 in damages.
The SC emphasized that to find the accused guilty of The RTC dismissed the charge against Singcol for injuring
qualified rape would violate the constitutional prohibition his sister-in-law’s son due to prescription, as over 15 years
against ex post facto laws, or laws that increase the penalty had passed since the crime.
after the crime has been committed.
People of the Philippines vs. Leopoldo Singcol | G.R. No.
275139, May 07, 2025 TITLE XII
CRIMES AGAINST THE CIVIL STATUS OF
Doctrine: Sudden outburst of uncontrolled emotions, PERSONS
triggered by years of abuse from the accused’s father, CHAPTER 2 – ILLEGAL MARRIAGES
qualifies as passion or
obfuscation – a mitigating circumstance that can reduce
the penalty for parricide.
Facts: Singcol was having breakfast when his father Erwin Bonbon vs. People of the Philippines | G.R. No.
arrived, carrying a bolo. An argument broke out, and his 272844, February 24, 2025
father attempted to attack him but stumbled and fell. Doctrine: A case for bigamy must be filed within 15 years
Singcol grabbed the bolo and stabbed his father in the from the time the second marriage is actually discovered,
chest, killing him. Shocked by what he had done, he held not just registered. Since bigamous marriages are often
kept secret, using the date of registration as the starting
point for the time limit would make prosecution “almost
impossible.
Facts: Records show that Erwin first married Gemma
Cunada in 1988. Without ending that marriage, he married
another woman in 1994 and then Elizabeth in 1999.
Erwin’s sisters learned about the third marriage in 2020
when they requested documents from the Philippine
Statistics Authority (PSA) to claim their late mother’s
benefits. They filed a bigamy case against Erwin and
Elizabeth in 2021, 22 years after Erwin’s marriage to
Elizabeth.
Erwin argued that the case was filed too late and had
prescribed, claiming his sisters already knew about the
marriage in 1999.
Held: The SC disagreed and upheld the rulings of both the
Regional Trial Court and Court of Appeals, which had
convicted Erwin of bigamy.
The SC explained that under the Revised Penal Code,
bigamy happens when a person who is still legally
married enters another marriage that appears to be
valid. A case for bigamy must be filed within 15 years
from the time the second marriage is actually
discovered, not just registered. Since bigamous
marriages are often kept secret, using the date of
registration as the starting point for the time limit
would make prosecution “almost impossible.”
In this instance, Erwin’s sisters learned about the marriage
only in 2020. He could not prove that they had been aware
of it since 1999 and admitted that no family members
attended the civil wedding, which took place in a different
province. The case filed in 2021 remained within the 15-
year legal limit.
Erwin was sentenced to up to eight years and one day in
prison.
