CASE DIGEST September 18, 2025 CRIMINAL LAW 2

Case Digest 1
Title: Trillanes IV v. Medialdea, et al.
Citation: G.R. No. 241494; decided April 3, 2024. Lawphil+2Supreme Court of the
Philippines+2

Facts
 Petitioner: Antonio “Sonny” F. Trillanes IV. Respondents: Salvador C. Medialdea (as
Executive Secretary), Delfin N. Lorenzana, etc. Supreme Court of the
Philippines+2Judiciary eLibrary+2
 Trillanes was charged with coup d’etat under Article 134-A of the RPC, for the
Oakwood Mutiny (2003) and the Manila Peninsula incident (2007), before the
Regional Trial Court of Makati (Branch 148) in Criminal Case No. 03-2784.
[Link]+2Lawphil+2
 He was granted amnesty by former President Benigno S. Aquino III under
Proclamation No. 75, series of 2010, which covered acts under RPC (and other laws)
in connection with those mutinies. [Link]+2Supreme Court of the
Philippines+2
 Later, President Rodrigo Duterte issued Proclamation No. 572 declaring that the
amnesty granted under Proclamation No. 75 to Trillanes was void ab initio, alleging
non-compliance with conditions (such as application and admission requirements,
and an admission of guilt). [Link]+2Supreme Court of the Philippines+2
 Trillanes challenged Proclamation No. 572 on constitutional grounds: the power to
grant and revoke amnesty, separation of powers, due process, double jeopardy, etc.
Supreme Court of the Philippines+2Judiciary eLibrary+2

Issues
1. Whether Proclamation No. 572 (revoking Trillanes’ amnesty) is valid, especially
whether the President may unilaterally revoke an already‐granted and finalized
amnesty, without Congress’ concurrence. Supreme Court of the
Philippines+2Studocu+2
2. Whether Proclamation No. 572 violates constitutional guarantees such as due
process or double jeopardy. Supreme Court of the Philippines+2Lawphil+2

Ruling (Supreme Court)

 The Supreme Court held that Trillanes’ amnesty under Proclamation No. 75 is valid,
and that Proclamation No. 572 revoking it is unconstitutional. Lawphil+2Supreme
Court of the Philippines+2
 Key reasonings/doctrines:
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

1. Shared power in granting amnesty: The Constitution requires Congressional

concurrence in granting amnesty (i.e. it’s not unilateral by the President
alone). Once amnesty is validly granted and becomes final, it may not be
revoked unilaterally. Supreme Court of the Philippines+1
2. Due process & double jeopardy: Revoking amnesty after it has been
perfected (i.e. after the grant has been fully implemented) violates
constitutional protection against double jeopardy and due process rights.
Supreme Court of the Philippines+1
3. On the factual preconditions (application, admission of guilt): The Court
examined whether Trillanes had complied with the formal requirements
under Proclamation No. 75 (application, acknowledgment of guilt). The Court
found that Trillanes did not admit guilt and also that no record of a formal
application exists. But even so, those facts do not justify revocation once the
amnesty grant has become final. The Court placed importance on the finality
of the grant. Supreme Court of the Philippines+2Studocu+2
 The Court also held that Proclamation No. 572 violated constitutional design insofar
as it usurped judicial power by trying to invalidate an amnesty that was judicially
recognized, and violated separation of powers. Supreme Court of the Philippines+1

Doctrine & Connection to Title 3, Book 2 RPC, Public Order Crimes

 Amnesty: Amnesty is a remedy/grant that applies to crimes, including crimes under
Title 3 of Book 2 of the RPC (such as rebellion, sedition, coup d’etat, mutiny etc.). As
such, this case affirms that an amnesty, once granted validly (with required
conditions and concurrence), cannot be revoked in a way that violates constitutional
guarantees.
 Coup d’etat under Article 134-A, RPC: The crimes for which Trillanes was charged
(mutiny / coup d’etat) are within Title 3 (Crimes Against Public Order). Thus, this case
is directly relevant to that Title: it deals with how executive/constitutional powers
(amnesty) interact with the prosecution of such public order crimes.
 Separation of Powers / Constitutional Limits: Even in the realm of public order
crimes, the exercise of powers like amnesty, revocation thereof, etc., is constrained
by due process, congressional concurrence, and respect for finality and judicial
power.

Case Digest 2
Title: Lagman, et al. v. Pimentel, et al.
Citation: G.R. No. 235935; decided February 6, 2018. Studocu+2Jur+2

Facts
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 Petitioners: Representatives Edcel C. Lagman, Tomasito S. Villarin, Gary C. Alejano,

Emmanuel A. Billones, Teddy Brawner Baguilat, Jr., and others. Respondents: Senate
President Aquilino Pimentel III, Speaker Pantaleon D. Alvarez, Executive Secretary
Salvador Medialdea, Defense Secretary Delfin N. Lorenzana, Budget Secretary
Benjamin E. Diokno, AFP Chief of Staff General Rey Leonardo Guerrero. Studocu+1
 On May 23, 2017, President Duterte issued Proclamation No. 216, declaring martial
law and suspending the privilege of the writ of habeas corpus in the whole of
Mindanao for 60 days, due to rebellion by Maute and Abu Sayyaf Groups. Studocu+1
 Congress approved the extension by Resolutions until December 31, 2017. Then
petitioners challenged the further extension for year 2018 (January 1 to December
31, 2018), arguing lack of sufficient factual basis etc. Studocu+2Jur+2

Issues
1. Whether the President and Congress had sufficient factual basis to extend
Proclamation No. 216 (martial law/suspension of habeas corpus) in Mindanao for
one year (2018). Studocu+1
2. Whether the manner in which Congress extended martial law and suspension did
violate any constitutional requirement (quorum, voting, deliberation, etc.).
Studocu+1

Ruling (Supreme Court)

 The Supreme Court upheld the constitutionality of the extension. The Court found
that:
1. Rebellion persists: Even after the retaking of Marawi City (which had been a
major theater of rebellion), there remained continuing armed resistance and
threats that justified extension. The Court held that rebellion is a continuing
crime, and might persist even when major hostilities cease in specific
localities. Studocu+1
2. Public safety requires extension: The Court held that the events,
circumstances, and information presented (intelligence reports, updated on
ground situation) sufficiently showed that public safety was endangered,
justifying extension. Studocu+1
3. Congress’ procedure in extending was valid: The rules adopted by the Joint
Session of both Houses, the resolutions, and the deliberations were
sufficiently constitutional; no substantial violation of quorum, voting or
publication was shown. Studocu+1

Doctrine & Connection to Title 3, Book 2 RPC, Public Order Crimes

CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 Definition/Doctrine of Rebellion: This case reaffirms that rebellion is a continuing

crime under Article ___ (this is under Title 3, Book 2). Rebellion does not cease
simply because a major battle has ended; its persistence or resurgence can trigger
constitutional responses like martial law.
 Martial Law & Suspension of Habeas Corpus: The case elaborates the standard
under Article VII, Section 18 of the 1987 Constitution: that martial law (and
suspension of habeas corpus) may be declared by the President upon the existence
of invasion or rebellion, and public safety requires it. The factual basis (probable
cause) for both invasion/rebellion and necessity for public safety must be present.
This is a constitutional doctrine related to public order crimes.
 Checks & Balances / Judicial Review: Although the President has broad power to
declare and extend martial law, the Supreme Court has authority to review whether
the factual basis exists; also Congress has a role (to approve/extend). This case
delineates limits for the exercise of those powers.

Case Digest 3
Title: People of the Philippines v. Ramoy, et al.
Citation: G.R. No. 212738; decided March 9, 2022. Lawphil+2Supreme Court of the
Philippines+2

Facts
 Petitioners: Atty. Anna Liza R. Juan-Barrameda, Mischaella Savari, and Marlon Savari.
Respondents: Rufino Ramoy and Dennis Padilla. Supreme Court of the
Philippines+2Jur+2
 The petitioners served as poll watchers during the 2010 Barangay Elections.
Scribd+2Lawphil+2
 On October 25, 2010, petitioners filed a complaint against Paul Ramones Borja for
premature campaigning (distributing election paraphernalia inside polling place,
soliciting votes). Later, on January 17, 2011, they filed another complaint charging
Ramoy and Padilla (who were then candidates) for conspiracy with Borja in
committing election violations. Scribd+1
 The Assistant City Prosecutor issued a resolution finding probable cause on February
18, 2011 to file informations. Three criminal informations were filed with the
Regional Trial Court of Quezon City, Branch 101, charging among others: violation of
Section 80 of the Omnibus Election Code (premature campaigning),
soliciting/campaigning on election day inside polling place, etc. Scribd+1
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 The petitioners ask the Supreme Court to annul and set aside the Court of Appeals
decision (and its resolution) which had quashed some orders of the RTC. Scribd+1

Issues
1. Whether the Court of Appeals correctly quashed the informations filed against
Ramoy and Padilla (and others) on the grounds that the actions are not covered by
the election law, or there were defects in the probable cause or procedure.
Jur+2Scribd+2
2. Whether petitioners (poll watchers) have the legal standing, or whether the acts
committed fall under criminal election violations under the Omnibus Election Code
which may be analogous to “crimes” or offenses under public order law. (The case
tests the boundary between election law and public order / criminal law.)

Ruling (Supreme Court)

 The Supreme Court Decision (March 9, 2022) affirmed the CA’s decision to quash
certain orders of the RTC. It held that the complaints/informations are insufficient or
defective in parts. Lawphil+2Supreme Court of the Philippines+2
 The Court found that some of the allegations did not adequately show violation of
the relevant provisions of the Election Code, or that the respondents were not
properly charged (i.e. the facts alleged did not constitute the crimes charged).
Lawphil+2Jur+2
 For those counts/informations properly filed, the Court left them intact; for others,
the Court affirmed the quashing or dismissal. Lawphil+1

Doctrine & Connection to RPC Title 3, Book 2

 This case is primarily about election law violations (Omnibus Election Code) rather
than direct application of the Revised Penal Code’s Title 3 public order crimes like
rebellion, sedition, illegal assembly, or direct assault. However:
o It illustrates how public order is affected by election disturbances, premature
campaigning, electioneering inside polling places, which are regulated to
preserve order during elections.
o The case shows that not all offenses affecting public order are prosecuted
under the RPC; some are under special laws (election law), and in such cases
the elements and proof must align strictly with those laws.
 The decision underscores the requirement of probable cause in filing informations
even for election-related public order disturbances, and how petitioners must
correctly allege facts that correspond to the law’s elements.
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 Even though this is not cleanly under RPC Title 3, the case helps distinguish when
behavior is punished under special laws vs when equivalent behavior might
constitute a “crime against public order” under RPC.

Case Digest 4
Title: Mallari y Samar v. People of the Philippines
Citation: G.R. No. 224679; decided February 12, 2020. Lawphil+2Jur+2

Facts
 Petitioner: Jonah Mallari y Samar. Respondent: People of the Philippines.
Lawphil+2Jur+2
 Information filed May 31, 2007, alleging that on January 12, 2007 in the City of
Olongapo, Mallari, being “visibly drunk,” got involved in an altercation of women
fighting in front of a billiard hall. Police officers in uniform arrived to pacify the
disturbance. Scribd+2Jur+2
 The officers asked the women to go to the station to file complaints, but Mallari
shouted at them, grabbed one officer (PO2 Navarro) by the collar, slapped his cheek,
and kicked his legs several times. The officer sustained a slight swelling of the
cheekbone. Mallari claimed police also used force against her (pulled her down,
grabbed ankles etc.). Lawphil+2Jur+2
 Trial courts (Municipal Trial Court then Regional Trial Court) found her guilty beyond
reasonable doubt of direct assault upon an agent of a person in authority (Article
148, RPC). The Court of Appeals affirmed with some modification (penalty). Mallari
then filed a Rule 45 petition before the Supreme Court. Scribd+2Jur+2

Issues
1. Whether Mallari’s acts (slapping, kicking, grabbing shirt / collar) while under
influence of alcohol, resisting police pacification, constitute direct assault under
Article 148 of the RPC, or rather the lesser offense of resistance and disobedience
under Article 151. Jur+1
2. Whether the force employed was “serious” enough (i.e. “grave or more intense”) to
satisfy the requisites of direct assault. The degree/seriousness of assault is key. Jur+1

Ruling (Supreme Court)

 The Supreme Court held that Mallari’s acts were not serious enough to constitute
direct assault under Article 148 RPC, but instead fall under resistance or disobedience
under Article 151. Jur+1
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 Therefore, Mallari’s conviction for direct assault was modified: she was found guilty
of Article 151 (resistance / disobedience) rather than Article 148. The penalty was
correspondingly lighter: arresto mayor, etc., plus a fine. Scribd+1
 The Supreme Court clarified the doctrine that in determining whether an offense is
direct assault vs resistance/disobedience, one must examine:
1. The seriousness of the force used (whether it is grave, dangerous, severe).
2. The identity of the victim (agent of a person in authority) and whether he/she
was in actual performance of official duties.
3. The surrounding circumstances: motive, gravity of resistance, degree of
defiance. Jur+1

Doctrine & Connection to RPC Title 3, Book 2

 Article 148 (Direct Assault upon Agents of Persons in Authority) & Article 151
(Resistance and Disobedience to a Person in Authority) are both under Title 3,
Crimes Against Public Order. This case helps define the boundary between those two
crimes.
 The doctrine from this case: when force is used against an agent of a person in
authority but is not serious/ grave or dangerous, then per RPC the proper crime is
resistance/disobedience (Art. 151), not direct assault (Art. 148). The seriousness of
force is a key test.
 This clarifies how courts should assess degree of force, identity and status of victim,
performance of duties etc., to decide which RPC crime applies.
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

Case Digest 5
Title: Pedro Pequero y Nollora v. People of the Philippines
Citation: G.R. No. 263676; decided August 7, 2024. Inquirer News+3Lawphil+3Studocu+3

Facts
 Petitioner: Pedro Pequero y Nollora. Respondent: the People of the Philippines.
Studocu+1
 In 2011, the National Bureau of Investigation (NBI) conducted an entrapment
operation following a report by a complainant, Ponciano Banjao, that Pequero was
falsely pretending to be a lawyer using the name “Atty. Epafrodito Nollora.”
Studocu+1
 During that operation, he was apprehended before the Municipal Trial Court (MTC)
of Binangonan. The presiding MTC judge cautioned him for usurpation of authority.
Lawphil+1
 A Joint Affidavit of Arrest was executed, and cases were filed against him:
1. Violation of Commonwealth Act No. 142 (as amended by RA 6085) — use of
illegal alias. Lawphil+1
2. Violation of Article 178, RPC — use of fictitious name. Lawphil+1
3. Violation of Article 177, RPC — usurpation of authority or official functions.
Studocu+1
 He denied these charges, arguing among others that he was really a lawyer, that the
identity of Epafrodito Nollora was said to be a deceased relative, and that at the time
of arrest he was only paying taxes at the court, not practicing law. Studocu+1
 On trial, the lower courts (MTC, then Regional Trial Court, then Court of Appeals)
found him guilty for the use of illegal alias, use of fictitious name, and usurpation of
authority. He appealed to the Supreme Court. Lawphil+1

Issues
1. Whether the CA gravely erred in affirming Pequero’s conviction for each of the
crimes charged: illegal alias, fictitious name, and usurpation of authority. Studocu+1
2. Specifically, whether the facts prove that he used an illegal alias/fictitious name,
misled people into believing he is a lawyer, and whether a lawyer qualifies as a
“person in authority” under RPC for purposes of usurpation of authority or official
functions. Studocu+1

Ruling (Supreme Court)

 The Supreme Court partly affirmed and partly reversed. Lawphil+1
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

o Affirmed the conviction for use of illegal alias. He used “Atty. Epafrodito
Nollora” although his legal birth name was Pedro Nollora Pequero. He did not
have authority to use that alias. Studocu+1
o Affirmed the conviction for use of fictitious name. Even though "Epafrodito
Nollora" is a real name, it belonged to a deceased person; using that name
with intent to represent oneself as something one is not, especially to clients
or in legal documents, is illegal under RPC Article 178. Penalty modified
(favorable to the petitioner) to arresto mayor. Studocu+1
o Acquitted him of usurpation of authority or official functions. The Court held
that even though he represented himself as a lawyer, a lawyer (private
lawyer) is not a “person in authority” under RPC for the crime of usurpation
of authority. The acts required for usurpation must be acts legally assigned
specifically to persons in authority/public officers; representing a private
right/role as lawyer does not make one a State authority for this purpose.
Studocu+1

Doctrine & Connection to RPC Title 3, Book 2

 Articles 177 & 178 of RPC are Crimes of Other Falsities, located under Title 3, Book 2
insofar as they concern public order/falsities affecting public confidence and order.
The case illustrates how these articles are applied:
o Illegal alias (CA No. 142 / RA 6085) vs RPC provisions: distinction between
alias use for entertainment/literary vs use to mislead public in serious
functions like law practice. Uses beyond those purposes are punishable.
o Use of fictitious name (RPC Article 178): when one uses a name that is not
his/her birth name (or registered name) to mislead or deceive the public,
especially in professional/legal capacity.
o Usurpation of authority (RPC Article 177): requires that the role being
usurped is inherently one of public authority (a public officer, or someone
otherwise invested with authority). Representation as a private profession
(lawyer) is not enough.
 The decision helps delineate the boundaries between what kinds of
impersonation/falsification constitute a crime under RPC, especially in relation to
maintaining public order/trust.

Case Digest 6
Title: People of the Philippines v. Glecerio Pitulan y Briones
Citation: G.R. No. 226486; decided January 22, 2020. Lawphil+2Jur+2

Facts
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 Accused-Appellant: Glecerio Pitulan y Briones. Plaintiff/Appellee: People of the

Philippines. Lawphil+2Studocu+2
 On April 20, 2003, police officers (PO1 De Vera, PO1 Dionisio, PO1 Monteroso) in full
uniform and in mobile patrol responded to a report of a suspicious group of men in a
van in Quezon City. Officers ordered the van to halt; driver (later identified as Pitulan)
gave chase. The van was eventually blocked; most occupants complied with orders,
except the driver. Studocu+2Jur+2
 PO1 Monteroso opened the door on the passenger side opposite the driver to check
on the driver. As he did so, Pitulan fired three shots at him, hitting him in the chest;
the officer died. Other passengers fought with other officers; a shootout ensued.
Pitulan attempted to escape but was intercepted. He was arrested; firearms and
ammunition were recovered. Studocu+1
 He was tried and convicted by the Regional Trial Court for the complex crime of
direct assault with murder, among other counts (attempted, frustrated murder etc.).
The CA affirmed. He then appealed to the Supreme Court. Studocu+1

Issues
1. Whether the killing of PO1 Monteroso was murder or a lesser offense (i.e., whether
aggravating circumstances like treachery were established). Lawphil+2Studocu+2
2. Whether the evidence (eyewitness testimony, etc.) was sufficient beyond reasonable
doubt to establish guilt, including identity, participation, and elements of direct
assault under RPC Article 148. Jur+1

Ruling (Supreme Court)

 The Supreme Court modified the conviction: He was found guilty, not of direct
assault with murder, but of direct assault with homicide (i.e. lesser degree, because
the aggravating circumstance of treachery was not proven). [Link]+1
 Penalty: An indeterminate sentence of prision mayor (minimum) to reclusion
temporal (maximum) was imposed. Studocu+1
 On evidence: The Court held that even if ballistic or paraffin tests were not provided,
eyewitness testimony (if credible) is sufficient to prove identity of accused and
corpus delicti. The accused’s bare denial is not enough to negate such testimony.
Studocu+1
 On treachery: It was not established because the officer was not taken completely by
surprise, given preceding chase and warnings; hence murder (which requires
treachery) could not be upheld. Studocu+1

Doctrine & Connection to RPC Title 3, Book 2

CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 Article 148, RPC: Direct Assault Upon Agents of Persons in Authority is the key
provision here. The case clarifies:
1. The modes of direct assault: either (a) an act equivalent to rebellion or
sedition (but no public uprising), or (b) via employing force/resisting a person
in authority while they are performing duties. This case is of the second
mode. Studocu+1
2. How aggravating circumstance of treachery is established (or not). The Court
is strict in applying it; it requires that the victim is caught by surprise and
cannot defend himself. Preceding chase and refusal to stop by the suspect
reduce the element of surprise. Studocu+1
3. Evidence: positive eyewitness ID can suffice notwithstanding absence of
ballistic test, so long as the witness is credible and consistent, and no
convincing evidence to the contrary. Bare denial by accused is insufficient.
Studocu+1
 The decision helps define the penalty and classification between direct assault with
murder vs direct assault with homicide (the latter when aggravating circumstances
like treachery are lacking). Both are public order crimes under Title 3.
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

Case Digest: Basilonia, et al. v. Villaruz, et al.

Citation: G.R. Nos. 191370-71; decided August 10, 2015. Lawphil+2Jur+2

Facts
 Petitioners (accused): Rodolfo Basilonia, Leodegario Catalan, and John “Jojo”
Basilonia. Respondent: Judge Villaruz, etc. Lawphil+2Jur+2
 They were convicted in 1987 (Roxas City) for multiple crimes:
1. Murder of Atty. Isagani Roblete (Article 248 RPC) committed September 15,
1983. Course Hero+1
2. Frustrated homicide (as principal) against Rene Gonzales, same date. Course
Hero+1
 The convictions became final. Decades later (circa 2009 onward), petitioners sought
to bar execution of the judgment, essentially arguing that the prescriptive period
(“prescription of penalties”) had run: that after 20 years, the State could no longer
enforce the sentence. Jur+2Digest PH+2

Issues
1. Whether, under Article 93 of the RPC (on prescription of penalties), the penalty
imposed by a final sentence becomes unenforceable after 20 years if the State does
not execute it. Jur+1
2. Whether the civil liability (indemnity, damages) following the criminal conviction is
also extinguished by prescription in the same way, or whether it survives beyond the
criminal penalty. Digest PH+1

Ruling (Supreme Court)

 The Supreme Court held that imprisonment is enforceable even after 20 years from
judgment, provided there has been no “evasion of sentence” (i.e. the convict has not
escaped while under the service of the sentence). Jur+1
 The Court likewise held that civil liability (indemnity, damages) does not prescribe in
the same way that criminal penalties do under Art. 93; civil obligations survive.
Lawphil+1

Doctrine & Connection to RPC Book 2, Title 3

 Prescription of penalties (Article 93, RPC): This case clarifies that prescription does
not automatically run simply by passage of time; there must be evasion (escape)
during the service of sentence. This is consistent across many criminal cases.
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

 It shows the difference between criminal penalty prescription and civil liability arising
from a crime: the criminal is subject to prescription under RPC; the civil is not
extinguished simply by prescription of penalty.
 Though the case is not about public order crimes (i.e. rebellion, sedition, illegal
assembly, etc.), it is relevant to RPC’s general provisions regarding penalties and how
execution of sentences works, which also apply to all crimes under RPC including
those under Title 3.

Case Digest: Pangan v. Gatbalite, et al.

Citation: G.R. No. 141718; decided January 21, 2005.
[Link]+4Lawphil+[Link]+4

Facts
 Petitioner: Benjamin Pangan y Rivera. Respondents: Hon. Lourdes F. Gatbalite
(Judge), and the warden of the city jail. Jur+1
 On September 16, 1987, Pangan was convicted of simple seduction. He was
sentenced to two months and one day of arresto mayor. On appeal, the RTC
affirmed the conviction on October 24, 1988. Scribd+1
 However, Pangan never served the sentence. He evaded or was absent for many
years (around nine years). Then, on January 20, 2000, he was arrested and detained
at the Mabalacat Detention Cell. On January 24, 2000, he filed a petition for habeas
corpus, arguing that the penalty had prescribed under Article 93 of the RPC, and that
his criminal liability was extinguished by virtue of his long evasion of service of the
sentence. [Link]+1

Issues
1. When does the prescriptive period (for criminal penalties) begin to run under Article
93 of the RPC in cases where the convict has never been committed to serve the
sentence (i.e. evasion)? More specifically, does “prescription” begin once the
judgment is final, or only when there is evasion while serving the sentence? Jur+1
2. Whether Pangan’s sentence had already prescribed, thus extinguishing the criminal
penalty and making his arrest and detention illegal under habeas corpus. Jur+1

Ruling (Supreme Court)

 The Court denied Pangan’s petition. It held that prescription of penalties does not
begin to run merely by the finality of the judgement, or by a convict being at large; it
requires evasion during the service of sentence (i.e. escape while serving a
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

deprivation of liberty). Since Pangan was never committed, he never evaded service
of sentence in the sense required for prescription to start. Scribd+1
 Thus, his penalty had not yet prescribed, and his criminal liability was not
extinguished. Scribd+1

Doctrine & Connection to RPC Book 2, Title 3

 Again, this is about prescription (RPC Article 93) rather than a specific public order
crime under Title 3. But the doctrine (about when prescription begins: when
sentence is being served, and where evasion occurs) is universally applicable to all
crimes under RPC, including public order crimes.
 Also, “simple seduction” is not a public order crime; it is a crime against honor or
chastity. So this case doesn’t directly interpret Title 3 provisions, but it’s relevant for
the mechanics of enforcing penal judgments generally.

Case Digest: Torres, et al. v. Director, Bureau of Corrections

Citation: G.R. No. 122338; decided December 29, 1995. Lawphil+2Scribd+2

Facts
 Petitioner: Wilfredo Sumulong Torres. Respondents: Director, Bureau of Corrections,
etc. Lawphil+2Scribd+2
 In 1979, Torres was convicted of estafa, and was granted a conditional pardon by the
President. The condition was that if Torres would violate any penal law again, the
sentence withheld under his pardon would be executed. Scribd+1
 Later (by 1982), Torres was convicted of sedition plus more estafa cases. Based on
that, the Board of Pardons and Parole recommended to the President that the
conditional pardon be canceled because Torres allegedly breached the condition by
committing new crimes. The President revoked/annulled the conditional pardon.
Torres’ family filed a petition for habeas corpus, seeking his release, arguing that the
cancellation of the pardon violated due process, etc. Scribd+1

Issues
CASE DIGEST September 18, 2025 CRIMINAL LAW 2

1. Whether the exercise by the President (upon recommendation by the Board of

Pardons and Parole) of cancelling a conditional pardon due to alleged commission of
new offenses violates due process, especially when those new convictions were still
or in part under appeal. Scribd+1
2. Whether such exercise of pardoning/pardon revocation is beyond judicial review or
constitutes a “grave abuse of discretion.” Lawphil+1

Ruling (Supreme Court)

 The Supreme Court dismissed the petition for habeas corpus. It upheld the
revocation of the conditional pardon, finding no grave abuse of discretion in
determining that Torres had breached the condition (by being convicted of sedition /
estafa). Lawphil+1
 The Court held that the President’s prerogative to grant pardons (including
conditional pardons) includes the authority to determine whether conditions have
been violated, and that such determination is, under the law, not immune from
review—but unless shown that the determination was made in error or arbitrarily,
courts will defer. Lawphil

Doctrine & Connection to RPC Book 2, Title 3

 Sedition is a public order crime under Title 3 of Book 2. So this case directly involves
a crime under Title 3. The revocation of conditional pardon because of sedition is
directly relevant to how Title 3 crimes are treated under executive clemency/pardon
powers.
 The case clarifies the constitutional / procedural limits on pardons: that conditional
pardons’ cancellation is possible when conditions are breached, and that the
beneficiary of a pardon must comply with the conditions.
 Also, it shows that the judiciary can review whether the conditions were breached,
but that courts accord respect to the President’s decision unless there is grave abuse
of discretion.