Gonzales v.

Abaya
G.R. No. 164007, 10 August 2006
Facts:
The case involves military personnel, including Lt. (SG) Eugene Gonzales, Lt. (SG) Andy
Torrato, and Lt. (SG) Antonio Trillanes IV, who were charged with coup d'etat related to the
Oakwood mutiny on July 27, 2003, in Makati City, Philippines. Over 300 armed junior officers
and enlisted men, led by Trillanes, seized the Oakwood Premier Luxury Apartments, disarmed
security guards, and planted explosives, protesting President Gloria Macapagal Arroyo’s
administration over issues like military corruption. The mutiny ended after negotiations, and
the soldiers surrendered.
The National Bureau of Investigation (NBI) recommended charging the petitioners with coup
d'etat, and the Department of Justice filed the charges with the Makati Regional Trial Court.
Simultaneously, the Armed Forces conducted its own investigation, charging the soldiers with
violations of the Articles of War. The petitioners argued that the charges were unrelated to
their military service and should be tried in a civilian court. The RTC ruled that the charges
were not service-connected and fell under the crime of coup d'etat. In response, the
petitioners filed a Petition for Prohibition with the Supreme Court to prevent a court-martial.
Issue:
Whether or not those charged with coup d'etat before RTC shall be charged before military
tribunal for violation of Articles of War.
Ruling:
Civil courts are typically used to try members of the Armed Forces of the Philippines (AFP)
who violate local ordinances, special laws, or the Revised Penal Code. A court martial is used
to try the case, though, if a civil court finds that the offense is related to service prior to
arraignment. The President may, in extraordinary cases, order a civil court to hear the case.
The petitioners are charged with professional misconduct related to their military service,
specifically a purported breach of their oath to defend the Constitution. Only a court martial
has the authority to administer the punishment for this infraction, which is dismissal from the
service. Since the law or Constitution has jurisdiction over such matters, not the Regional Trial
Court (RTC), the RTC erred in ruling that this offense was not service connected. This is a
serious abuse of discretion. Furthermore, because the offenses involve different statutes, the
doctrine of absorption of crimes—which normally applies when crimes are punished under the
same statute—does not apply in this case. Additionally, since R.A. The doctrine is not
applicable because 7055 denies civil courts jurisdiction over offenses related to military
service, such as Article 96 of the Articles of War.
People v. Tulin
G.R. No. 111709, 30 August 2001, 364 SCRA 10
Facts:
On March 2, 1991, the cargo vessel "M/T Tabangao," owned by PNOC Shipping and Transport
Corporation, was hijacked off the coast of Mindoro by seven armed pirates led by Emilio
Changco, the older brother of Cecilio Changco, one of the accused. The pirates took control of
the vessel, forced the crew to paint over its name and logo, and sailed to Singapore. They
sent misleading messages to PNOC, but after failing to meet another vessel, they returned to
the Philippines and transferred the cargo to another vessel, "Navi Pride," under the
supervision of Cheong San Hiong. The crew was eventually released on April 10, 1991. The
incident was reported, and the accused individuals were arrested in May 1991. They were
charged with qualified piracy under Presidential Decree No. 532 and, on October 24, 1991,
were sentenced to reclusion perpetua and ordered to pay damages. The case was later
elevated to the Supreme Court
Issue:
Whether or not the accused-appellant Hiong was guilty of piracy?
Ruling:
Hiong was found guilty of piracy under the laws governing such offenses. Article 122 of the
Revised Penal Code, prior to its amendment, defined piracy as crimes committed on the high
seas by individuals who were not members or passengers of the vessel. However, with the
amendment through Republic Act No. 7659, the law was expanded to cover piracy occurring
in Philippine waters as well. Additionally, Presidential Decree No. 532, issued in 1974,
broadened the scope of piracy laws to include any person involved in the crime, regardless of
whether they were a passenger or a member of the crew, specifically within Philippine waters.
Republic Act No. 7659 did not invalidate or alter the provisions of Presidential Decree No. 532;
rather, it expanded the scope of piracy laws to protect citizens and neighboring countries from
crimes under international law. These two laws are not contradictory but complement each
other, with each providing distinct but harmonious legal coverage for piracy offenses.
People v. Lol-lo and Saraw
G.R. No. 17958, 27 February 1922
Facts:
On June 30, 1920, two boats departed from Matuta to Peta in Dutch territories. One boat
carried a lone individual, while the other held eleven Dutch nationals, including men,
women, and children. Near the islands of Buang and Bukid in the Dutch East Indies, the
second boat was ambushed by twenty-four Moros in six vintas, who demanded food, seized
cargo, assaulted passengers, and committed heinous violations against two women before
sabotaging the boat. The passengers survived after eleven days at sea, though the women
were abducted and subjected to continuous abuse. Two of the perpetrators, Lol-lo and
Saraw, later returned to South Ubian, Tawi-Tawi, in the Philippines, where they were arrested
and charged with piracy. Despite a defense challenge to the court’s jurisdiction, they were
tried, convicted, and sentenced to life imprisonment, with restitution ordered for the stolen
goods.
Issue:
1. Whether the elements of the crime of piracy as defined by the law were present in the
defendants’ actions.
Ruling:
The Supreme Court affirmed that piracy is a crime against all mankind (hostes humani
generis) and can be prosecuted in any competent tribunal regardless of territorial
jurisdiction. It upheld the applicability of the Spanish Penal Code’s provisions on piracy in
the Philippines, asserting their continued validity following the Treaty of Paris and the
transfer of sovereignty, as long as they were not inconsistent with U.S. laws or the Philippine
Constitution. The Court substituted references to “Spain” and “Spaniards” with “United
States” and “citizens of the United States and the Philippine Islands,” ensuring these laws
remained effective. Considering aggravating and mitigating circumstances, the Court
sentenced Lol-lo to death but upheld Saraw’s life imprisonment due to a lack of unanimous
agreement, alongside ordering restitution for the victims.
AAA v. BBB
G.R. No. 212448, 11 January 2018
Facts:
AAA, a flight attendant, and BBB, a chef in Singapore, married in the Philippines in 2006
and had two children. After moving to Singapore, BBB allegedly had an affair and
subjected AAA to mental and emotional abuse, including a violent incident in a
Singapore hotel in 2011. Upon returning to the Philippines, AAA filed charges under the
Anti-Violence Against Women and Their Children Act (RA 9262). The Pasig Regional Trial
Court (RTC) issued a warrant for BBB's arrest, but BBB evaded capture, leading to the
case’s archiving. BBB later moved to quash the case, arguing the RTC lacked jurisdiction
since the alleged acts occurred in Singapore. The RTC granted the motion, ruling that
jurisdiction depends on where the abusive acts physically occurred. AAA elevated the
matter to the Supreme Court, asserting that her mental and emotional suffering
continued in the Philippines, thus giving the RTC jurisdiction over the case.
Issue:
1. Whether the Philippine courts have jurisdiction over an offense constituting
psychological violence under R.A. No. 9262 when the alleged extramarital affair
occurred outside the country.
2. Whether the RTC’s grant of the motion to quash on the ground of lack of jurisdiction
stands or the case should be reinstated.
Ruling:
The Supreme Court granted AAA’s petition, reversed the RTC’s resolutions, and
reinstated the Information in Criminal Case No. 146468. It ruled that psychological
violence under R.A. No. 9262 is a transitory or continuing crime, meaning the offense’s
completion can occur in multiple locations. While marital infidelity constituted the act of
psychological violence, the resulting mental or emotional anguish—an essential
element of the offense—occurred wherever the victim resides. Since AAA and her
children experienced the anguish in Pasig City, the RTC of Pasig City has jurisdiction.
The Court clarified that R.A. No. 9262 punishes psychological violence causing mental or
emotional suffering, not infidelity itself. It further emphasized that jurisdiction attaches
to any court where a significant part of the offense, including its effects, takes place,
allowing the complainant to choose the venue.
- Benedicto v. CA, G.R. No. 125359, 4 September 2001

Facts:

On December 27, 1991, Imelda Marcos, Roberto S. Benedicto, and Hector T. Rivera were
charged with violations of Central Bank (CB) Circular No. 960, related to Section 34 of the
Central Bank Act, for failing to report and register foreign exchange earnings. Initially, five
cases (Criminal Cases Nos. 91-101879 to 91-101883) were filed at the RTC of Manila, followed
by nine more cases on the same day and eleven additional cases on January 3, 1992, all
alleging similar violations involving significant sums in foreign banks. These cases were
consolidated before Branch 26 of the RTC.

Subsequent amendments to the rules governing foreign exchange transactions under CB

Circular Nos. 1318 and 1353 included saving clauses for pending cases. Benedicto and Rivera
returned to the Philippines in 1993 under conditional terms and posted bail. In 1994, they
moved to quash the Informations, citing lack of jurisdiction and immunity under a Compromise
Agreement, but the RTC denied the motion. Their appeal to the Court of Appeals (CA) led to the
dismissal of one case (Criminal Case No. 91-101884) but upheld the rest. Dissatisfied, they
elevated the matter to the Supreme Court, challenging the CA’s decision.

Issue:

1. Whether or not the RTC have jurisdiction and was there improper forum shopping?
2. Whether or not the repeal of CB Circular No. 960 and Republic Act No. 265 extinguish the
criminal liability of petitioners?
3. Whether or not the criminal cases already prescribed?
4. Whether or not the petitioners exempt from the CB reporting requirement?
5. Whether or not the Compromise Agreement grant absolute immunity from prosecution for
the alleged violations?

Ruling:

The Supreme Court upheld the dismissal of the petition and affirmed the CA’s decision, except
for the dismissal of charges against Roberto S. Benedicto due to his death on May 15, 2000. It
ruled that the RTC had jurisdiction, as Presidential Decree No. 1606, in effect at the time of
filing, allowed regular courts to try the offenses. There was no forum shopping since the same
act violated distinct laws penalizing different aspects of the offenses. Despite the repeal of CB
Circular No. 960 and Republic Act No. 265, subsequent laws and circulars retained similar
provisions, and saving clauses preserved pending cases.
The eight-year prescriptive period was calculated from the discovery of the violations in 1986
after the EDSA Revolution, not the transaction dates. Petitioners' claim of exemption under
Republic Act No. 6426 was denied due to insufficient evidence that their accounts qualified.
The claim of absolute immunity under a Compromise Agreement was also rejected, as it did
not cover the CB Circular No. 960 violations. Jurisdiction is determined by the law in force at
filing; saving clauses in repeals protect pending cases; no forum shopping occurs when
separate laws penalize distinct offenses; prescription runs from discovery when concealment is
involved; immunity applies only to cases explicitly covered

________________________________________________________________________________________________

- White Light Corp. v. City of Manila, G.R. No. 122846, 20 January 2009

Facts:

On December 3, 1992, Manila enacted City Ordinance No. 7774, signed by then-Mayor Alfredo
S. Lim, prohibiting short-time room rates in hotels, motels, and similar establishments to
protect public morals and curb activities like prostitution and drug use. Petitioners White Light
Corporation (WLC), Titanium Corporation (TC), and Sta. Mesa Tourist and Development
Corporation (STDC), operators of motels under the Anito Group of Companies, challenged the
ordinance, arguing it unlawfully interfered with their businesses.

The Regional Trial Court (RTC) of Manila issued a Temporary Restraining Order (TRO) and later a
preliminary injunction against the ordinance’s enforcement, ultimately declaring it
unconstitutional for arbitrarily infringing on private rights without sufficient justification.
However, on appeal, the Court of Appeals reversed the RTC’s ruling, upholding the ordinance
as a valid exercise of police power. The petitioners then elevated the case to the Supreme
Court for final adjudication

Issue:

1. Whether the petitioners have the legal standing to challenge the ordinance.
2. Whether the ordinance violates the right to privacy and freedom of movement.
3. Whether the ordinance is a valid exercise of police power.
4. Whether the ordinance is unconstitutional and void for being an unreasonable and
oppressive interference in the business of the petitioners.

Ruling:

The Supreme Court granted the petition, reversed the Court of Appeals' ruling, and reinstated
the RTC's decision declaring Manila's Ordinance No. 7774 unconstitutional. The Court upheld
the petitioners' legal standing, recognizing their right to protect their business interests and
their patrons’ constitutional rights, applying the overbreadth doctrine to challenge the
ordinance on behalf of affected clients. It ruled that the ordinance infringed on the privacy and
freedom of movement of consenting adults engaging in legitimate sexual activity.
________________________________________________________________________________________________

- Garcia v. Drilon, G.R. No. 179267, 25 June 2013

Facts:

Rosalie Jaype-Garcia filed a petition for a Temporary Protection Order (TPO) against her
husband, Jesus C. Garcia, citing physical, emotional, psychological, and economic abuse under
Republic Act No. 9262, the "Anti-Violence Against Women and Their Children Act." The
petitioner admitted to extramarital affairs, controlling behavior, and abuse that led the private
respondent to attempt suicide. He also dominated family businesses while neglecting financial
support for his family. The Bacolod Regional Trial Court issued multiple TPOs to protect Rosalie
and her children.

In response, Jesus C. Garcia filed a petition with the Court of Appeals (CA) challenging the
constitutionality of R.A. 9262, arguing it violated the equal protection and due process clauses
and improperly delegated judicial power to barangay officials. The CA dismissed the petition,
ruling that constitutional issues cannot be raised for the first time on appeal and that the
challenge constituted a prohibited collateral attack on the law’s validity.

Issues:

1. Whether the petition for prohibition was the proper remedy to assail the constitutionality of
R.A. 9262..

Ruling:

The Supreme Court affirmed the dismissal of the petition, upholding the constitutionality of
Republic Act No. 9262 (R.A. 9262) and the Temporary Protection Orders (TPOs) issued under it.
The Court ruled that challenges to a law’s constitutionality must be raised at the earliest
opportunity and that a petition for prohibition is not the proper means to contest interlocutory
orders like a TPO. It held that R.A. 9262’s classification is not arbitrary or discriminatory, as it
addresses the distinct experiences of women in domestic violence situations.

_______________________________________________________________________________________________
_

- Guingguing v. People, G.R. No. 128959, 30 September 2005.

Facts:

The Supreme Court affirmed the convictions for libel against Ciriaco “Boy” Guingguing and
Segundo Lim but clarified the principles governing freedom of expression and the limits of self-
defense in defamation cases. The Court upheld the lower courts' rulings, finding that the
advertisement published in the Sunday Post, which included details and photos suggesting
criminal involvement by broadcast journalist Cirse “Choy” Torralba, was defamatory and
malicious.

The Court rejected Lim's defense of self-defense, holding that retaliatory defamation cannot be
justified, especially when it exceeds proportional limits and attacks a person's reputation
beyond the original provocation. It emphasized that media professionals, while subject to
public scrutiny, are still entitled to protection from malicious publications. The decision
reinforced the principle that the exercise of free speech and press freedom carries
responsibilities and boundaries, particularly regarding false and damaging statements. The
penalties, as modified by the Court of Appeals, were upheld, balancing the need for
accountability with considerations of proportionality in libel cases.

Issue:

1. Whether or not the advertisement in question was indeed libelous.

Ruling:

The Supreme Court acquitted Ciriaco "Boy" Guingguing and Segundo Lim of libel, ruling that
the statements published were not made with actual malice and fell within the bounds of
constitutional protections for free speech. The Court emphasized that libel involves the
malicious imputation of a discreditable act or circumstance through publication, and malice is a
key element. While the publication contained critical statements about Cirse "Choy" Torralba,
these were based on truthful information sourced from public records, negating malice.

________________________________________________________________________________________________

- US v. Bustos, L-12592, 8 March 1918

Facts:

In December 1915, thirty-four citizens of Pampanga, including councilors and property owners,
accused Justice of the Peace Roman Punsalan of bribery and misconduct through a petition
submitted to the Executive Secretary. The case was referred for investigation, and while initial
findings supported some allegations, Punsalan was later acquitted after a motion for a new
trial and further review. In October 1916, a libel case was filed against the petitioners, alleging
their accusations were defamatory. The trial court found most of them guilty, imposing fines or
subsidiary imprisonment. On appeal, the petitioners contested the libel charges, the rejection
of their evidence, and argued that their petition was a privileged communication aimed at
addressing public misconduct.

Issue:
1. Whether the defendants, by their petition and affidavits, committed libel against Justice of
the Peace Roman Punsalan.

Ruling:

The Supreme Court acquitted the defendants, ruling that their actions were protected under
the constitutional freedoms of speech, press, assembly, and petition. The Court emphasized
the critical role of public critique in a democratic society and found that the defendants'
statements were made in good faith, without malice, and with the legitimate intent of
addressing alleged corruption by a public official. It affirmed the qualified privilege to critique
public officials in the interest of improving governance and ensuring accountability. This case
reinforced the principle that good-faith criticism of public officials, aimed at accountability and
public service improvement, does not constitute libel and is protected under the Constitution.

________________________________________________________________________________________________

- Estrada v. Escritor, AM No. P-02-1651, 22 June 2006, 492 SCRA 1

Facts:

The case centers on a complaint filed on July 27, 2000, by Alejandro Estrada against Soledad S.
Escritor, a court interpreter at the RTC of Las Piñas City, Philippines. Estrada accused Escritor of
a relationship with Luciano Quilapio, Jr., claiming it compromised court integrity. Escritor, a
widow and Jehovah's Witness, defended her actions, citing religious beliefs. The administrative
case aimed to determine if cohabitation was "disgraceful and immoral conduct" under the
Revised Administrative Code. The case was brought before the Philippine Supreme Court after
a lengthy legal process.

Issue:

1. Whether Escritor’s conjugal arrangement constitutes “disgraceful and immoral conduct.”

Ruling:

The Supreme Court ruled in favor of Soledad S. Escritor, promoting her right to religious
freedom. The court acknowledged Escritor's sincerity and found no compelling interest to
interfere with her practices. The court dismissed her administrative complaint, stating that her
fundamental right to religious freedom outweighed the alleged misconduct. This case
reinforces the doctrine of benevolent neutrality and the compelling state interest test,
emphasizing that religious practices should only be limited when they harm vital state
interests.______________________________________________________________________________________
___

- People v. Echagaray, G.R. No. 117472, 7 February 1997, 267 SCRA 682

Facts:
Leo Echegaray y Pilo was convicted in 1994 for raping his daughter under Republic Act No.
7659, the Death Penalty Law. He filed a Motion for Reconsideration, which was denied by the
Supreme Court. He later changed legal counsel and enlisted the Anti-Death Penalty Task Force
of the Free Legal Assistance Group (FLAG), which filed a Supplemental Motion for
Reconsideration. The motion raised issues such as potential pardon, vague offense date,
doubts about guilt, misidentification, due process violations, and constitutional concerns over
the death penalty.

Issue:

1. Whether the Supplemental Motion for Reconsideration introduced new issues improperly at
the reconsideration stage

Ruling:

The Supreme Court ruled in favor of Leo Echegaray, rejecting new arguments and ensuring
fairness in his trial. The court upheld the constitutionality of Republic Act No. 7659, reinstating
the death penalty, stating it provided clear standards for defining heinous crimes and allowed
Congress to impose it for compelling reasons. The court also rejected the claim that the death
penalty, particularly for rape, constituted cruel or unusual punishment, emphasizing the law's
sufficient safeguards and procedural requirements.

________________________________________________________________________________________________

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

Facts:

Danilo Tangcoy entrusted jewelry worth P98,000 to Lito Corpuz, who failed to remit the sale
proceeds or return unsold items within 60 days. Corpuz was charged with estafa under Article
315 of the Revised Penal Code. Despite denying the charge, he was found guilty by the
Regional Trial Court and sentenced. The Court of Appeals upheld the conviction, with a
modification regarding the prison term. Corpuz appealed to the Supreme Court, arguing the
case focused on estafa issues and criminal liability.

Issue:

1. Whether photocopies of prosecution evidence admitted by the lower courts violate the best
evidence rule.

Ruling:

The Supreme Court upheld Lito Corpuz's conviction for estafa, stating that Corpuz waived his
objection to photocopies due to timely submission and the complete information in the charge.
The prosecution established Danilo Tangcoy's demand and upheld his credibility. The elements
of estafa with abuse of confidence were proven beyond reasonable doubt, affirming Corpuz's
conviction.

________________________________________________________________________________________________

- Lozano v. Martinez, L-63419, 18 December 1986

Facts:

Petitioners are arguing that the Bouncing Check Law (BP 22) should be classified as a "bad
debt law" rather than a "bad check law" to curb the practice of issuing worthless checks. The
law penalizes individuals who issue checks knowing they lack sufficient funds or credit to cover
the check upon presentation, leading to the check being dishonored by the bank. The offense
is not viewed as a crime against property but as an offense against public order.

Issue:

Whether or not the Batas Pambansa Bilang 22 (BP 22 for short), popularly known as the
BouncingCheck Law is valid and constitutional.

Ruling:

The Supreme Court ruled that lawmakers can prohibit acts harmful to public welfare, even if
they are not inherently wrong. BP 22 was enacted to protect the public from social and
economic harm caused by dishonored checks. The Court emphasized that checks are
commercial instruments essential to the banking system, subject to state regulation to protect
public order.

________________________________________________________________________________________________

- People v. Ferrer, L-32613-14, 27 December 1972, 48 SCRA 382

Facts:

The Anti-Subversion Act, which criminalized membership in the Communist Party of the
Philippines, was challenged by Feliciano Co and Nilo Tayag for being unconstitutional. The trial
court deemed the statute void, leading to an appeal to the Supreme Court, which will
determine the law's validity and potential constitutional rights conflict.

Issue:

1. Whether the Anti-Subversion Act constitutes a bill of attainder.

Ruling:

The Supreme Court upheld the constitutionality of the Anti-Subversion Act, rejecting the trial
court's ruling that it was a bill of attainder. The Act targets conduct, not just membership in an
organization, and only those with the intent to advance illegal goals of the Communist Party of
the Philippines would be liable. The court affirmed that legislation criminalizing active
membership in subversive organizations was not constitutional.

________________________________________________________________________________________________
- US v. Diaz Conde, L-18208, 14 February 1922

Facts:

In 1915, Oliveros and Lianco borrowed ₱300 from Diaz Conde and Apolinaria R. de Conde,
agreeing to pay 5% monthly interest. After the Usury Law was enacted, they were arrested,
arraigned, and pleaded not guilty. The trial found them guilty, imposing a fine and subsidiary
imprisonment.

Issue:

1. Whether the Usury Law (Act No. 2655) could be retroactively applied to contracts executed
prior to its enactment.

Ruling:

The Supreme Court of the Philippines ruled that the Usury Law cannot be applied retroactively
to a contract executed before its enactment, violating constitutional prohibitions against
impairing contracts and violating ex post facto laws. The court overturned the lower court's
decision, dismissed the complaint, and ordered the release of Vicente Diaz Conde and
Apolinaria R. de Conde.

________________________________________________________________________________________________

- People v. Arcega, G.R. No. 237489, 27 August 2020

Facts:

Domingo Arcega was convicted of attempted rape by the RTC of Iriga City, but the Court of
Appeals modified the conviction to acts of lasciviousness. The Solicitor General filed a petition
for review on certiorari, arguing that the CA erred in modifying the conviction and failed to
recognize the clear intent to commit rape. Arcega argued that the CA's modification acquitted
him of attempted rape, violating his constitutional right against double jeopardy, based on
legal principles, evidence standards, and procedural recourse.

Issue:

Whether petitioner seeks a review on certiorari of the CA Decision, which modified the RTC
Judgment, convicting the respondent of attempted rape due to acts of lasciviousness.

Ruling:

The Supreme Court denied a petition for review on certiorari, stating that the Solicitor
General's appeal violated the respondent's constitutional right against double jeopardy. The
Court reiterated that a judgment of acquittal is final, unappealable, and immediately executory.
The Court clarified that errors of judgment can be reviewed under Rule 45, but not under Rule
65. The Court upheld the Court of Appeals' ruling, stating that double jeopardy barred the
State from appealing an acquittal.

________________________________________________________________________________________________
- People v. Abilong, L-1960, 26 November 1948.

Facts:

The Supreme Court ruled that Florentino Abilong's entry into Manila, despite violating his
sentence, did not constitute evasion under Article 157 of the Revised Penal Code, which
penalizes evasion of service of sentence by convicts who escape from imprisonment. The
decision led to the reversal of the lower court's ruling, which had convicted Abilong under
Article 157.

Issue:

1. Whether evasion of the service of a sentence of destierro comes under Article 157 of the
Revised Penal Code.

Ruling:

The Supreme Court clarified the interpretation of "privación de libertad" under Article 157 of
the Revised Penal Code, stating that the original Spanish text takes precedence over English
translations in ambiguous cases. Florentino Abilong's willful entry into Manila, punishable
under destierro, was upheld, reinforcing the broader interpretation of deprivation of liberty.

________________________________________________________________________________________________

- Hernan v. Sandiganbayan, G.R. No. 217874, 5 December 2017.

Facts:

Ophelia Hernan was convicted for malversation of public funds during her time as a cashier at
the Department of Transportation and Communication. The case was based on irregularities in
deposit slips and subsequent investigations. Hernan's attempts to challenge her conviction
were unsuccessful, and she filed a petition for certiorari under Rule 65, alleging grave abuse of
discretion by the Sandiganbayan. The Supreme Court's resolution will depend on Hernan's
ability to prove the Sandiganbayan's actions.

Issue:

1. Whether the Sandiganbayan erred in concluding that the motion to reopen was filed out of
time, considering extraordinary circumstances surrounding the case.

Ruling:

The Supreme Court denied Ophelia Hernan's petition for certiorari due to procedural
improperity and insufficient claims to reopen the case. The court reiterated the principle of
finality of judgments and reminded litigants and their counsel to monitor case developments
and update contact information to avoid procedural lapses. The decision emphasizes the
importance of adhering to procedural rules and legislative reforms.

________________________________________________________________________________________________

- Inmates of the New Bilibid Prison, Muntinlupa City v. De Lima, G.R. No. 212719, June 25, 2019

Facts:
The case revolves around the retroactive application of Republic Act No. 10592, which
introduced lenient sentence reduction provisions under the Revised Penal Code. The
petitioners, represented by Attorney Michael J. Evangelista, argued that this violated Article 22
of the RPC, which requires penal laws favorable to the accused to apply retroactively.

Issue:

1. Whether Section 4, Rule 1 of the IRR, which mandates the prospective application of
benefits introduced by R.A. No. 10592, is legal under Article 22 of the RPC.

Ruling:

The Supreme Court ruled that Republic Act No. 10592's benefits, including Good Conduct Time
Allowance, must apply retroactively to all eligible inmates, including those convicted before the
law's enactment. The court deemed the proposed application unconstitutional, violating
legislative intent, equal protection, and substantive due process.

________________________________________________________________________________________________

-People v. Formigones, L-3246, 29 November 1950

Facts:

Abelardo Formigones stabbed his wife Julia Agricola in 1946, causing severe lung damage and
death. He confessed, citing jealousy and suspicion of Julia's infidelity. Initially guilty, he later
pleaded not guilty and claimed imbecility, supported by jail guard testimony.

Issue:

1. Whether Abelardo Formigones is exempt from criminal liability due to imbecility under
Article 12 of the Revised Penal Code.

Ruling:

The Supreme Court upheld Abelardo Formigones's parricide conviction, recognizing mitigating
circumstances. The court found Abelardo was feeble-minded but not entirely deprived of
reason or discernment. The court recognized feeble-mindedness and jealousy-induced passion,
reducing the penalty from death to reclusion perpetua. The decision clarified criminal liability
standards, emphasizing the importance of mitigating circumstances and executive clemency in
cases involving remorse or mental limitations.