1. Case Name: People of the Philippines v. De Lima (G.R. No. 212719 and G.R. No.

214637)
Date: December 8, 2015
Court: Supreme Court of the Philippines

Summary:
This case revolves around the interpretation of Republic Act No. 10592 (R.A. 10592),
which amended certain provisions of the Revised Penal Code (RPC) regarding the computation
of good conduct time allowance (GCTA) for prisoners. Specifically, the case questions the
validity of Section 4, Rule 1 of the Implementing Rules and Regulations (IRR) of R.A. 10592,
which directs the prospective application of the grant of GCTA, time allowance for study,
teaching, and mentoring, and special time allowance for loyalty.
Facts:
• On May 29, 2013, then-President Benigno S. Aquino III signed R.A. 10592 into law,
amending Articles 29, 94, 97, 98, and 99 of the RPC.
• R.A. 10592 introduced changes to the computation of GCTA for prisoners.
• Section 4, Rule 1 of the IRR of R.A. 10592 directed that the new rules on GCTA and
related allowances should have prospective application, meaning they should not benefit
prisoners whose cases had been decided before the law's enactment.
• Several prisoners, through their representatives and counsel, filed petitions challenging
the prospective application of the law, arguing that it violated Article 22 of the RPC,
which allows retroactive application of beneficial penal laws.
• The petitioners contended that the prospective application of R.A. 10592 was
unconstitutional, as it deprived them of benefits they would have otherwise received if
the law was applied retroactively.
Issues:
1. Whether the prospective application of R.A. 10592, as provided in the IRR, is
unconstitutional.
2. Whether the petitioners have legal standing to challenge the law.
Ruling:
1. The Supreme Court ruled in favor of the petitioners, declaring Section 4, Rule 1 of
the IRR of R.A. 10592 invalid. The Court held that R.A. 10592 should be applied
retroactively because it is a penal law favorable to the accused, consistent with Article
22 of the RPC. The law aimed to benefit prisoners by reducing their sentences
through the GCTA, and therefore, its provisions should be applied retroactively to
their advantage. The Court found that the IRR's prospective application contradicted
the intent of the law itself.
 2. The Court recognized the legal standing of the petitioners, as they were directly
affected by the prospective application of R.A. 10592. Their imprisonment would
potentially be shortened if the law was applied retroactively, making them parties
with a direct interest in the case.

Impact:
This case established that penal laws, especially those beneficial to the accused, should
be applied retroactively in accordance with Article 22 of the RPC. It clarified the legal standing
of prisoners to challenge laws that directly affect their sentences and rights. As a result, prisoners
who were eligible for GCTA under R.A. 10592 were entitled to have their sentences recalculated
and potentially reduced, leading to their early release from prison if they had already served their
sentences with the GCTA credits.

2. This case, G.R. No. 212719 and G.R. No. 214637, involves a legal challenge to the validity
of Section 4, Rule 1 of the Implementing Rules and Regulations (IRR) of Republic Act No.
10592, which relates to the application of good conduct time allowance (GCTA) and other
time allowances for prisoners. The case centers around whether this provision should be
applied retroactively or prospectively.
Background:
1. On May 29, 2013, President Benigno S. Aquino III signed into law Republic Act
No.
10592, which amended certain articles of Act No. 3815, also known as the Revised Penal Code
(RPC). This law pertained to the computation of time allowances for prisoners based on their
good conduct while in detention.
2. Following the enactment of R.A. No. 10592, the Department of Justice (DOJ) and
the Department of the Interior and Local Government (DILG) issued the Implementing
Rules and Regulations (IRR) on March 26, 2014, which became effective on April 18,
2014.
3. Several individuals, including inmates and their representatives, filed legal
petitions questioning the validity of Section 4, Rule 1 of the IRR, specifically challenging
its prospective application. They argued that the provision contradicted Article 22 of the
Revised Penal Code, which provides that penal laws beneficial to the accused should
have retroactive effect.
4. The key issue in this case revolved around whether the provision in the IRR of
R.A. No. 10592 should be applied retroactively, allowing prisoners to receive the benefits
of the law immediately, or prospectively, applying it only to future cases.
Ruling: The Supreme Court ruled in favor of the petitioners and declared Section 4, Rule 1 of the
IRR invalid insofar as it provided for prospective application. The Court's decision was based on
the principle that penal laws favorable to the accused should have retroactive effect, as long as
the accused is not a habitual criminal. The Court found that the standard of "good conduct" for
granting time allowances remained consistent over the years and that it was not complex for
prison authorities to retroactively apply R.A. No. 10592 based on existing prison records.
The Court ordered the Director General of the Bureau of Corrections and the Chief of the Bureau
of Jail Management and Penology to promptly recompute the time allowances for the petitioners
and others in similar situations and to release them immediately if they have served their
sentences in full, unless they are being detained for other lawful reasons.
The decision was considered immediately executory, meaning it should be enforced without
delay.
In summary, this case involved a legal dispute over whether a provision in the Implementing
Rules and Regulations of Republic Act No. 10592, related to time allowances for prisoners,
should be applied retroactively or prospectively. The Supreme Court ruled in favor of retroactive
application based on the principle that penal laws favorable to the accused should have
retroactive effect, and it ordered the release of affected prisoners who have served their
sentences.

FACTS:
May 29, 2013 - President Benigno S. Aquino III signed into law R.A. No. 10592,
amending Articles 29, 94,97, 98 and 99 of Act No. 3815, or the Revised Penal Code (RPC).IRR
was jointly issued by respondents Department of Justice (DOJ) Secretary Leila M. De Lima and
Department of the Interior and Local Government (DILG) Secretary Manuel A. Roxas II on
March 26,2014 and became effective on April 18, 2014. Petitioners and intervenors assail the
validity of its Section 4, Rule 1 that directs the prospective application of the grant of good
conduct time allowance (GCTA), time allowance for study, teaching and mentoring (TASTM),
and special time allowance for loyalty (STAL) mainly on the ground that it violates Article 22 of
the RPC. On June 18, 2014, a Petition for Certiorari and Prohibition (with Prayer for the
Issuance of a Preliminary Injunction) was filed by Atty. Evangelista, attorney-in-fact of the
petitioners, against respondents DeLima and Roxas. They contend that the provisions of R.A.
No. 10592 are penal in nature and beneficial to the inmates; hence, should be given retroactive
effect in accordance with Article 22 of the RPC. Further, they contend that IRR contradicts the
law it implements. Petitioners submit that the simple standards added by the new law, which are
matters of record, and the creation of the Management, Screening and Evaluation Committee
(MSEC) should not override the constitutional guarantee of the rights to liberty and due process
of law aside from the principle that penal laws beneficial to the accused are given retroactive
effect. Atty. Rene Saguisag Sr. filed a petition for intervention and argued that Section 4, Rule I
of the IRR is facially void for being contrary to the equal protection clause of the 1987
Constitution; it discriminates, without any reasonable basis, against those who would have been
benefited from the retroactive application of the law; Page 4 of 18 and is also ultra vires, as it
was issued beyond the authority of respondents to promulgate
Oct. 2014, Petition for Certiorari and Prohibition was filed by Edago et al, who are all
inmates at the Maximum Security Compound of the NBP, against the respondents. They contend
that: Sec. 4 of Rule I, IRR provides for a prospective application of the provisions of 10592 and
was issued with grave abuse of discretion amounting to lack or excess of jurisdiction and thereby
void and illegal for being contrary and anathema to RA 10592 and that:
a. R.A. 10592 does not state that its provisions shall have prospective application.
b. Section 4 of the IRR of R.A. 10592 is contrary to Article 22 of the Revised Penal
Code
providing that penal laws that are beneficial to the accused shall have retroactive application.
c. Section 4, Rule I of the IRR contravenes public policy and the intent of Congress
when it enacted R.A. 10592
Section 4, rule I of the IRR was issued by respondents with grave abuse of discretion
amounting to lack or excess of jurisdiction because it is patently unconstitutional and:
a. Section 4, rule I of the IRR violates the equal protection clause of the constitution.
b. Section 4, rule I of the IRR violates substantive due process.

3.) ATTY. HOWARD M. CALLEJA, et al. v. EXECUTIVE SECRETARY, et al. (G.R. No.
252578, December 07, 2021)

Facts:

• Petitioners, including lawyers Atty. Howard M. Calleja, Atty. Joseph Peter J.

Calleja, and Atty. Christopher John P. Lao, De La Salle Brothers Inc.
represented by Br. Armin A. Luistro, FSC, Dr. Reynaldo J. Echavez, Napoleon
L. Siongco, and Raeyan M. Reposar, filed a petition challenging the
constitutionality of Republic Act No. 11479, known as the Anti-Terrorism Act
of 2020 (ATA).
 • The ATA was signed into law on July 3, 2020, and petitioners argued that it
violates several provisions of the Constitution.
• Petitioners argued that the ATA's definition of terrorism is overbroad and
vague, potentially criminalizing protected speech and expression. They also
claimed that it violates the right to due process, freedom of expression, and
equal protection under the law.
• Specifically, they challenged the provisions allowing the warrantless arrest
and detention of suspected terrorists for up to 24 days, the prescription of
terrorist organizations, and the ex parte designation of individuals or groups as
terrorists by the Anti-Terrorism Council (ATC).
• Petitioners sought a Temporary Restraining Order (TRO) and/or Writ of
Preliminary Injunction to prevent the implementation of the ATA.

Issues:

1. Whether or not the Anti-Terrorism Act of 2020 violates the right to freedom of
expression.
2. Whether or not the ATA violates the right to due process.
3. Whether or not the ATA gives law enforcement agencies too much discretion.
4. Whether or not a TRO and/or Writ of Preliminary Injunction should be issued to
prevent the implementation of certain provisions of the ATA.

Court’s Ruling: bill of rights section: 1, 4, 12, 14

Section 22 – bill of attainder and ex post facto
1. Right to Freedom of Expression:

• The Court held that the ATA, on its face, does not violate the right to freedom
of expression. It punishes only speech that incites to terrorism or threatens to
commit terrorism.
• The Court emphasized that advocacy, protest, dissent, stoppage of work,
industrial or mass actions, and other similar exercises of civil and political
rights are not acts of terrorism.
• It stated that the ATA's definition of terrorism is narrowly drawn and does not
penalize protected speech.
 2. Right to Due Process:

• The Court found that the ATA has sufficient safeguards to protect the right to
due process.
• It ruled that the provisions regarding designation of terrorist individuals or
groups, detention without judicial warrant, and proscription of terrorist
organizations have procedural safeguards in place, such as judicial review and
the right to be heard.

3. Discretion of Law Enforcement Agencies:

• The Court held that the ATA does not give law enforcement agencies
unbridled discretion. It outlined specific requirements and procedures for the
enforcement of the law.
• The Court also emphasized the importance of judicial review in preventing
abuse of discretion.

4. Temporary Restraining Order and Preliminary Injunction:

• The Court denied the prayer for a TRO and/or Writ of Preliminary Injunction.
• It found that petitioners failed to show that they have a clear and unmistakable
right that needs protection or that there is an urgent need to prevent irreparable
injury.

Conclusion:

• The Court upheld the constitutionality of most provisions of the AntiTerrorism

Act of 2020 but clarified that it should not be interpreted to suppress protected
speech, protests, or civil and political rights.
• Petitioners' plea for a TRO and/or Preliminary Injunction was denied.

This case underscores the balance between national security and the protection of civil
liberties in anti-terrorism legislation, emphasizing the importance of narrowly drawn definitions
and procedural safeguards.

4. G.R. Nos. L-32613-14, December 27, 1972

PEOPLE OF THE PHILIPPINES, petitioner, vs. HON. SIMEON FERRER (in his capacity
as Judge of the Court of First Instance of Tarlac, Branch I), FELICIANO CO alias
LEONCIO CO alias "Bob," and NILO S. TAYAG alias Romy Reyes alias "Taba,"
respondents. Solicitor R. Mutuc for respondent Feliciano Co. Jose W. Diokno for
respondent Nilo Tayag.

PONENTE:

• CASTRO, J.

NATURE OF THE CASE:

• A criminal complaint for violation of section 4 of the Anti-Subversion Act was

filed against respondent Feliciano Co in the Court of First Instance of Tarlac.

FACTS:

• On March 5, 1970, a criminal complaint was filed against Feliciano Co,

alleging that he had feloniously become an officer and/or ranking leader of the
Communist Party of the Philippines. He was also accused of being an
instructor in the Mao Tse Tung University, the training school of recruits of
the New People's Army, the military arm of the Communist Party of the
Philippines.
• Co moved to quash the complaint, arguing that the Anti-Subversion Act is a
bill of attainder.
• On May 25, 1970, another criminal complaint was filed with the same court,
charging respondent Nilo Tayag and five others with becoming officers of
Kabataang Makabayan, a subversive organization. They were accused of
conducting meetings to instigate the people to rise in arms and overthrow the
Government by force.
• On July 21, 1970, Tayag moved to quash the complaint, impugning the
validity of the statute on various grounds, including that it is a bill of attainder.
• The Regional Trial Court (RTC), in its resolution on September 15, 1970,
declared the statute void on the grounds that it is a bill of attainder, vague, and
 overbroad. The RTC also dismissed the information against the two accused.
The Government appealed, and the appeal was treated as a special civil action
for certiorari.

ISSUE:

• Whether the Anti-Subversion Act is a Bill of Attainder?

RULING:

• NO. The Court held that the Anti-Subversion Act is not a bill of attainder.
• Article III, section 1 (11) of the Constitution prohibits bills of attainder or ex
post facto laws. A bill of attainder is a legislative act that inflicts punishment
without trial. It substitutes a legislative for a judicial determination of guilt,
violating the principle of separation of powers.
• In this case, the Anti-Subversion Act does not specify the Communist Party of
the Philippines (CPP) for the purpose of punishment; it uses the CPP for
definitional purposes only.
• The Act emphasizes the prohibited conduct, not a specific class.
• The Act is insufficient to classify as a Bill of Attainder because it doesn't apply
solely to the CPP but to other organizations with the same purpose of
overthrowing the government.
• The guilt of the accused will still be judicially determined; courts must prove
that the accused "knowingly" joined the party and intended to overthrow the
government.
• The Act's judgment about the criminal nature of the Communist Party is
judicially noticeable.
• A bill of attainder requires retroactive application, reaching past conduct. The
Anti-Subversion Act applies prospectively; it punishes acts committed after its
approval in 1957.

LEGAL BASIS/JARGONS:
• Sec. 2 of the Anti-Subversion Act: The Congress declares the Communist
 Party of the Philippines as an organized conspiracy to overthrow the
Government and declares it and other organizations with the same purpose
illegal.
• Sec. 4 of the Act requires the government to prove knowing, willful, and direct
participation in unlawful activities through judicial proceedings.
• The Act applies prospectively, after its approval in 1957. It provides for the
exemption of members who renounce their membership in writing and under
oath.
Nature of the Case:

This case involves a criminal complaint filed against the respondents Feliciano Co and
Nilo Tayag for alleged violations of the Anti-Subversion Act. The primary issue revolves around
whether the Anti-Subversion Act is unconstitutional as a bill of attainder.

Facts:

1. On March 5, 1970, a criminal complaint was filed against Feliciano Co, accusing him of
becoming an officer and/or ranking leader of the Communist Party of the Philippines and
of being an instructor at the Mao Tse Tung University, the training school for recruits of
the New People's Army (NPA), the armed wing of the Communist Party.
2. Feliciano Co moved to quash the complaint, asserting that the Anti-Subversion Act is a
bill of attainder.
3. On May 25, 1970, a separate criminal complaint was filed against Nilo Tayag and five
others. They were charged with becoming officers of Kabataang Makabayan, a
subversive organization, and conducting meetings to incite people to overthrow the
government by force.
4. Tayag moved to quash the complaint, challenging the validity of the statute on various
grounds, including that it is a bill of attainder.
5. The Regional Trial Court (RTC) declared the Anti-Subversion Act void on the grounds
that it is a bill of attainder and that it is vague and overbroad. The charges against both Co
and Tayag were dismissed.
6. The government appealed the RTC's decision to the Supreme Court.

Issue:

Whether the Anti-Subversion Act constitutes a bill of attainder and is therefore

unconstitutional.

Ruling:

The Supreme Court, in its ruling, determined that the Anti-Subversion Act is not a bill of
attainder and is constitutionally valid. Here are the key points of the ruling:
 1. Definition of Bill of Attainder: A bill of attainder is a legislative act that imposes
punishment without a judicial trial. It substitutes a legislative determination of guilt for a
judicial one. The Constitution prohibits bills of attainder to prevent legislative usurpation
of the judicial function.
2. Legislative Intent: The Anti-Subversion Act does not specify the Communist Party of the
Philippines (CPP) for the purpose of punishment but uses it for definitional purposes. It
emphasizes prohibited conduct rather than targeting a specific class of individuals.
3. Application to Multiple Organizations: The Act applies not only to the CPP but also to
other organizations with the same goal of overthrowing the government. It does not
exclusively target the CPP.
4. Judicial Determination of Guilt: The Act does not automatically declare guilt. It mandates
that guilt be judicially determined based on the accused's "knowing, willful, and overt
acts" of affiliating themselves with the proscribed organizations.
5. Prospective Application: The Act applies prospectively, not retroactively, as it only
punishes those who affiliate themselves with the prohibited groups after its enactment.

Based on these considerations, the Supreme Court ruled that the Anti-Subversion Act is
not a bill of attainder and does not violate the Constitution. The case was remanded to the RTC
for trial on the merits.

Legal Basis/Jargons:

 • Anti-Subversion Act: Refers to the law under consideration in this case, which

 aimed to suppress subversive organizations.

• Bill of Attainder: A legislative act that inflicts punishment on individuals or groups without a
judicial trial.
• Communist Party of the Philippines (CPP): The organization implicated in the case as a
subversive group.
• Kabataang Makabayan: Another organization mentioned in the case, accused of subversive
activities.
• Prospective Application: Refers to the fact that the law applies to actions committed after its
enactment, not retroactively to past conduct.

G.R. No. 212448,

January 11, 2018

Parties:

• Petitioner: AAA
 • Respondent: BBB

Facts:

• AAA and BBB were married on August 1, 2006, in Quezon City, and had two
children.
• In May 2007, BBB began working in Singapore as a chef and obtained
permanent resident status there in September 2008.
• AAA claimed that BBB sent little to no financial support, leading her to work
extra hours as a flight attendant to support their family.
• AAA also alleged mistreatment, physical and sexual violence by BBB.
• BBB was accused of having an affair with a woman named Lisel Mok in
Singapore, which allegedly led to an altercation between AAA and BBB in a
hotel room in Singapore on April 19, 2011.
• The Information filed against BBB accused him of causing AAA mental and
emotional anguish through his alleged marital infidelity, a violation of the
Anti-Violence Against Women and their Children Act of 2004 (R.A. No.
9262).

CASE DIGEST: G.R. No. 212448, January 11, 2018

Title: AAA v. BBB**

Decision by: TIJAM, J.

Background:

• AAA and BBB were married on August 1, 2006, in Quezon City, and they had two children.
• In May 2007, BBB began working in Singapore as a chef and obtained permanent resident status
there in September 2008.
• AAA alleged that BBB sent little to no financial support, leading her to work extra hours as a
flight attendant to support their family.
• AAA also alleged mistreatment, physical, and sexual violence by BBB.
• BBB was accused of having an affair with a woman named Lisel Mok in Singapore, which
allegedly led to an altercation between AAA and BBB in a hotel room in Singapore on April
19, 2011.
• The Information filed against BBB accused him of causing AAA mental and emotional anguish
through his alleged marital infidelity, a violation of the AntiViolence Against Women and
their Children Act of 2004 (R.A. No. 9262).
• Procedural History:
• AAA filed a case against BBB in the Regional Trial Court (RTC) of Pasig City, Branch 158, for
violating R.A. No. 9262.
• The RTC issued a warrant of arrest against BBB, but he evaded arrest, and the case was archived.
• BBB filed a motion to quash, arguing that the RTC lacked jurisdiction over the case since the
alleged acts occurred outside the Philippines.
• The RTC granted the motion to quash, dismissing the case on the grounds that it lacked
jurisdiction over an offense that happened outside its territorial jurisdiction.
• AAA filed a motion for reconsideration, which was denied.
• AAA then filed a petition for certiorari before the Supreme Court, arguing that R.A. No. 9262
should apply, even if the alleged illicit relationship occurred outside the Philippines, as long
as she suffered mental and emotional anguish within the Philippines.

Issue:

• Can Philippine courts exercise jurisdiction over an offense constituting psychological violence
under R.A. No. 9262, committed through marital infidelity, when the alleged illicit
relationship occurred or is occurring outside the country?

Ruling:

• The Supreme Court ruled in favor of AAA and held that Philippine courts can exercise
jurisdiction over an offense of psychological violence under R.A. No.
• 9262, even if the alleged marital infidelity took place outside the Philippines.
• The Court clarified that R.A. No. 9262 criminalizes the psychological violence causing mental or
emotional suffering on the wife, and not the marital infidelity per se.
• Jurisdiction is determined by the allegations in the complaint or information. In this case, since
the offended wife and children were residents of Pasig City, the RTC of Pasig City had
jurisdiction over the case.
• The Court emphasized that the mental or emotional suffering of the victim is an essential element
of the offense, and it must be established that the victim is a resident of the place where the
complaint is filed.
• The Court ordered the reinstatement of the Information against BBB and set aside the RTC's
resolutions.

Legal Basis:

• The Supreme Court's decision is based on the interpretation of the Anti-Violence Against Women
and their Children Act of 2004 (R.A. No. 9262).
• Jurisdiction in criminal cases is determined by the allegations in the complaint or information and
the location where the offense or its essential elements occurred.
• The mental or emotional suffering of the victim is an essential element of the offense of
psychological violence under R.A. No. 9262.
• The law allows for the filing of a case where any of the crime's essential and material acts
occurred. This includes transitory or continuing crimes where some acts took place in one
location and some in another.
• The Court also emphasized the need to resolve doubts in favor of the offended party when
interpreting laws aimed at protecting victims of violence against women and children.

Summary:

This case involved the question of whether Philippine courts could exercise jurisdiction
over a case of psychological violence under the Anti-Violence Against Women and their Children
Act of 2004 (R.A. No. 9262) when the alleged marital infidelity causing the mental and emotional
anguish occurred outside the country. The Supreme Court ruled that Philippine courts had
jurisdiction over such cases if the victim, in this case, AAA, was a resident of the place where the
complaint was filed, even if the illicit relationship occurred abroad. The Court emphasized that
the law criminalizes the psychological violence that causes mental or emotional suffering, not the
marital infidelity itself. Therefore, the mental or emotional suffering experienced by the victim
within the Philippines is an essential element of the offense. The Court ordered the reinstatement
of the charges against the respondent, BBB.

FACTS:

• AAA filed a case against BBB in the Regional Trial Court (RTC) of Pasig City,
Branch 158, for violating R.A. No. 9262.
• The RTC issued a warrant of arrest against BBB, but he evaded arrest, and the
case was archived.
• BBB filed a motion to quash, arguing that the RTC lacked jurisdiction over the
case since the alleged acts occurred outside the Philippines.
• The RTC granted the motion to quash, dismissing the case on the grounds that it
lacked jurisdiction over an offense that happened outside its territorial jurisdiction.
• AAA filed a motion for reconsideration, which was denied.
• AAA then filed a petition for certiorari before the Supreme Court, arguing that
R.A. No. 9262 should apply, even if the alleged illicit relationship occurred
outside the Philippines, as long as she suffered mental and emotional anguish
within the Philippines.

Issue:
 • Can Philippine courts exercise jurisdiction over an offense constituting
psychological violence under R.A. No. 9262, committed through marital
infidelity, when the alleged illicit relationship occurred or is occurring outside
the country?

Ruling:

• The Supreme Court ruled in favor of AAA and held that Philippine courts can
exercise jurisdiction over an offense of psychological violence under R.A. No.
9262, even if the alleged marital infidelity took place outside the Philippines.
• The Court clarified that R.A. No. 9262 criminalizes the psychological
violence causing mental or emotional suffering on the wife, and not the
marital infidelity per se.
• Jurisdiction is determined by the allegations in the complaint or information.
In this case, since the offended wife and children were residents of Pasig City,
the RTC of Pasig City had jurisdiction over the case.
• The Court emphasized that the mental or emotional suffering of the victim is
an essential element of the offense, and it must be established that the victim is
a resident of the place where the complaint is filed.
• The Court ordered the reinstatement of the Information against BBB and set
aside the RTC's resolutions.

Legal Basis:

• The Supreme Court's decision is based on the interpretation of the Anti-

Violence Against Women and their Children Act of 2004 (R.A. No. 9262).
• Jurisdiction in criminal cases is determined by the allegations in the complaint
or information and the location where the offense or its essential elements
occurred.
• The mental or emotional suffering of the victim is an essential element of the
offense of psychological violence under R.A. No. 9262.
• The law allows for the filing of a case where any of the crime's essential and
material acts occurred. This includes transitory or continuing crimes where
some acts took place in one location and some in another.
 • The Court also emphasized the need to resolve doubts in favor of the offended
party when interpreting laws aimed at protecting victims of violence against
women and children.

Case Name: People of the Philippines v. Alfonso Gatchalian

Case Number: 104 Phil. 664
Date: December 29, 1958
Court: Supreme Court of the Philippines
Judge: Bautista Angelo, J.

Facts:
 Alfonso Gatchalian, the accused, was charged with four counts of violating Section 3 of
Republic Act No. 602 in the Court of First Instance of Zamboanga. The charges were
related to his operation of the New Life Drug Store in the City of Zamboanga and his
alleged failure to pay the prescribed minimum wages to his employee Expedite Fernandez
from August 4, 1951, to December 31, 1953. The specific violation charged was that
Gatchalian willfully and feloniously paid Expedite Fernandez a monthly salary of P60 to
P90 during the mentioned period, which was less than that required by law, resulting in an
unpaid salary of P1,016.64.
 Upon his arraignment, Gatchalian pleaded not guilty to the charges. Subsequently, he filed
a motion to dismiss, contending that the violations alleged did not constitute a criminal
offense and that the section of the law he was charged under did not specify any penalty
for the alleged violation. The City Attorney of Zamboanga filed an answer to the motion,
arguing that the law imposed both civil and criminal liability for violations and that the
penalty for willful violations was covered in Section 15 of Republic Act No. 602. After
hearing arguments from both parties and members of the local bar, the court issued an
order dismissing the informations against Gatchalian, canceling his bail bond, and
directing the Department of Labor to initiate a civil action against him for the collection
of the alleged underpayment.
 The government appealed the dismissal of the charges.
Legal Issues:
 1. Whether the violations alleged under Section 3 of Republic Act No. 602 constitute a
criminal offense.
2. Whether Section 15 of Republic Act No. 602 imposes both civil and criminal liability
for violations of the Minimum Wage Law.
3. Whether the court erred in dismissing the informations against Gatchalian.
Ruling:
1. The Supreme Court held in favor of the government, setting aside the order of
dismissal by the lower court and remanding the case for further proceedings. The key
points in the Court's decision were as follows:
2. Criminal Offense: The Court found that the violations alleged under Section 3 of
Republic Act No. 602, specifically the failure to pay the prescribed minimum wages,
constituted violations of the law.
3. Civil and Criminal Liability: The Court affirmed that Section 15 of Republic Act No.
602 imposed both civil and criminal liability for violations of the Minimum Wage
Law. It noted that the law explicitly stated that any person who willfully violates any
of the provisions of the Act could be subject to a fine or imprisonment or both.
4. Interpretation of the Law: The Court emphasized that the purpose of the Minimum
Wage Law was to provide a living wage for employees and that the law should be
interpreted to achieve this objective. It rejected the argument that the law was
ambiguous and should be strictly construed against the State, stating that Section
15(a) was clear and unambiguous in covering violations of Section 3, which set the
minimum wage.
5. Informations: The Court ruled that the informations filed against Gatchalian did not
need to specify the particular penal provision penalizing the offense, as long as they
followed the requirements set out in the Rules of Court.
In conclusion, the Court held that the lower court had erred in dismissing the charges against
Gatchalian, and the case was remanded for further proceedings. The Court emphasized the
importance of upholding the Minimum Wage Law to protect labor and ensure that employees
receive fair wages.

G.R. No. 74259, February 14, 1991

vs. PEOPLE OF THE PHILIPPINES, respondent.
petitioner.
GENEROSO P. CORPUZ, petitioner,
Law Firm of Roberto P. Halili for
CRUZ, J.:

FACTS:
 Generoso P. Corpuz, the petitioner, was employed as Supervising Accounting Clerk in the
Office of the Provincial Treasurer of Nueva Vizcaya. He was later designated Acting
Supervising Cashier in the same office, where he was responsible for receiving
collections, disbursing funds, and making bank deposits and withdrawals pertaining to
government accounts.
 On April 13, 1981, Corpuz's designation as Acting Supervising Cashier was terminated,
and on April 22, 1981, a Transfer of Accountabilities was conducted, which revealed a
shortage of P72,823.08. Corpuz was required to produce the missing amount but was only
able to pay P10,159.50. The balance was demanded through a letter dated October 12,
1981.
 On September 27, 1982, a final letter of demand for the total deficiency of P50,596.07
was sent to Corpuz. When he failed to meet this demand, an information for malversation
of the said amount was filed against him with the respondent court on October 11, 1983.
 Corpuz admitted the shortage but claimed that he was not guilty because the missing
funds were malversed by other individuals. He specifically alleged that the bulk of the
shortage, amounting to P50,000.00, represented an unliquidated withdrawal made by
Paymaster Diosdado Pineda through a check issued and encashed while Corpuz was on
official leave of absence.
ISSUE:
The primary issue in this case is whether Generoso P. Corpuz is guilty beyond reasonable
doubt of the crime of Malversation of Public Funds.
RULING:
The Supreme Court ruled that Corpuz is guilty of Malversation of Public Funds based on
the following findings:
 The evidence showed that Check No. 958525, which constituted a significant portion of
the shortage, was not immediately recorded in Corpuz's cash book, indicating an attempt
to hide the shortage. This omission was seen as a subtle way of camouflaging the
embezzlement of the money.
 While Corpuz claimed that he was absent on the dates when the checks were issued and
encashed, witnesses contradicted this claim. Specifically, Diosdado
o Pineda, a prosecution witness, testified that Corpuz was present on the critical
dates. Additionally, Corpuz's Employee's Leave Card indicated that he earned
vacation and sick leave during December 1980, undermining his claim of absence.
 Corpuz did not file any case or take any action against Pineda or others he accused of
misappropriation, casting doubt on the veracity of his allegations.
 The absence of a post-audit was not deemed fatal in this case because what determines
whether the crime of malversation has been committed is the presence of certain
requirements under Article 217 of the Revised Penal Code, including the fact that the
 offender was a public officer, had custody or control of public funds, and appropriated or
permitted another person to take those funds.
 In conclusion, Corpuz's conviction for malversation of public funds was affirmed by the
Supreme Court, as the evidence overwhelmingly supported the finding that he
misappropriated the missing funds. His claims of being a victim of persecution and
conspiracy were not found convincing, and his conviction was upheld.
LEGAL BASIS:
The legal basis for this case is the Revised Penal Code of the Philippines, particularly
Article 217, which defines and penalizes the crime of Malversation of Public Funds. The court's
decision was based on a thorough examination of the evidence presented and its application of the
relevant provisions of the law.

G.R. No. 148965 377 SCRA 538

JOSE "JINGGOY" E. ESTRADA, petitioner,

vs.
SANDIGANBAYAN (THIRD DIVISION), PEOPLE OF THE PHILIPPINES and OFFICE
OF THE OMBUDSMAN, respondents.
February 26, 2002

FACTS:

 In connection with the impeachment proceedings against President Joseph Estrada, five
criminal complaints were filed against him, members of his family, associates, friends,
and conspirators in the Office of the Ombudsman. The Respondent Ombudsman found
probable cause to file several criminal information with the Sandiganbayan against the
former President and other respondents. Among these charges was the crime of plunder
under R.A. 7080, and petitioner Jinggoy Estrada was one of the respondents.
 Petitioner filed a "Very Urgent Omnibus Motion" arguing that there was no probable
cause to put him on trial for plunder. He claimed that he was allegedly involved in illegal
gambling but not in a "series or combination of overt or criminal acts" as required by R.A.
7080. Additionally, he asserted that he was entitled to bail as a matter of right.
 The Sandiganbayan denied petitioner's motion, and he subsequently moved for
reconsideration of the resolution. The respondent court denied the motion and proceeded
to arraign petitioner.
ISSUE:
Whether or not the crime of plunder is proper.
HELD:
1. Multiple Acts Charged: Contrary to petitioner's contention, he was not charged with
the commission of only one act. The amended information used the phrase "on several
instances," indicating that petitioner allegedly committed the predicate act in series.
Therefore, it cannot be said that he was charged with the commission of only one act.
 This interpretation aligns with the popular, not technical, meaning of the words
"combination" or "series" in the context of R.A. 7080.
2. Conspiracy: In the crime of plunder, different parties may be united by a common
purpose. In this case, the various accused and their different criminal acts share a
common goal: assisting the former President in amassing, accumulating, or acquiring
ill-gotten wealth. While American jurisdiction distinguishes between "wheel or circle
conspiracy" and "chain conspiracy," the case appears to resemble a wheel conspiracy.
Former President Estrada serves as the hub, while the spokes represent all the accused,
and the rim encloses their common goal of accumulating ill-gotten wealth.
3. Conspiracy as a Mode of Committing a Crime: In Philippine jurisdiction, conspiracy
may be alleged as a mode of committing a crime or as constitutive of the crime itself.
When conspiracy is charged as a crime, it must be set forth in detail in the complaint
or information. However, when it is charged as a mode of committing a crime, as in
this case, less specificity is required because conspiracy is not the primary offense.
Instead, it changes the criminal liability of all the conspirators, making them co-
principals regardless of their degree of participation. The liability is collective, and
each participant is equally responsible for the acts of others.
In this case, the information alleged the conspiracy of the accused with the former
President in general terms, using words like "in connivance/conspiracy with his co-
accused." These words were deemed sufficient to allege conspiracy in committing the
crime of plunder.
In conclusion, the court upheld the charges against petitioner Jinggoy Estrada for plunder
and rejected his claims that only one act was charged and that conspiracy was inadequately
alleged. The case highlighted the collective liability of conspirators in plunder cases and
clarified the sufficiency of conspiracy allegations in the information.