Case Digest (G.R. No. 113092)
Facts:
In Martin Centeno vs. Hon. Victoria Villalon-Pornillos and the People of the Philippines, petitioner Martin Centeno, chairman of the Samahang Katandaan ng Nayon ng Tikay, Bulacan, joined co-accused Vicente Yco and Religio Evaristo in a fund drive during late 1985 to renovate the barrio chapel of Tikay. Without securing a permit from the Department of Social Welfare and Development as required by Presidential Decree No. 1564 (the Solicitation Permit Law), Centeno and Yco solicited ₱1,500 from Judge Adoracion G. Angeles, a local resident. Judge Angeles filed a complaint, leading to an information in the Municipal Trial Court (MTC) of Malolos (Criminal Case No. 2602). Their motion to quash, arguing that PD 1564 covered only charitable or public welfare solicitations and not religious ones, was denied by the MTC, which subsequently convicted Centeno and Yco on December 29, 1992, imposing a ₱200 fine each and recommending executive clemency for good faith. On appeal, the Regional TriCase Digest (G.R. No. 113092)
Facts:
- Formation and Fund Drive
- In late 1985, officers of the Samahang Katandaan ng Nayon ng Tikay—a civic organization of elderly residents of Barrio Tikay, Malolos, Bulacan—initiated a fund drive to renovate the local chapel.
- Petitioner Martin Centeno, as chairman, together with Vicente Yco, solicited a P1,500.00 contribution from Judge Adoracion G. Angeles without first securing a permit from the Department of Social Welfare and Development (DSWD) as required under Presidential Decree No. 1564.
- Criminal Proceedings in the Municipal Trial Court (MTC)
- Based on Judge Angeles’s complaint, an information for violation of P.D. 1564 was filed against Centeno, Yco, and Religio Evaristo before the MTC of Malolos, Branch 2 (Criminal Case No. 2602).
- The MTC denied the motion to quash the information and, after trial, found Centeno and Yco guilty beyond reasonable doubt on December 29, 1992. Each was fined ₱200.00, with a recommendation for executive clemency due to their good faith.
- Appeal to the Regional Trial Court (RTC)
- Yco withdrew his appeal, leaving Centeno as sole appellant in RTC Branch 10, Malolos.
- On May 21, 1993, the RTC affirmed the conviction but increased Centeno’s penalty to six months’ imprisonment and a ₱1,000.00 fine, denying reconsideration.
- Petition for Certiorari to the Supreme Court
- Centeno challenged whether solicitations for a religious purpose (chapel renovation) fall within the ambit of P.D. 1564’s “charitable or public welfare purposes.”
- He argued that the statute does not expressly include religious solicitations, that penal laws must be strictly construed in favor of the accused, and that applying P.D. 1564 to religious solicitations impinges on the constitutional right to free exercise of religion.
Issues:
- Whether solicitations made for a religious purpose are covered by Presidential Decree No. 1564’s requirement of a DSWD permit for contributions “for charitable or public welfare purposes.”
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)