G.R. No. L-2873 - People vs. Garcia y Madrigal

The case involves the People of the Philippines as plaintiff/appellee versus Eugenio Garcia y Madrigal as defendant/appellant.
The sole issue on appeal was whether the appellant, being 17 years of age at the time of the commission of the crime, was entitled to the privileged mitigating circumstance provided under Article 68, paragraph 2, of the Revised Penal Code (RPC).

At trial, the appellant was found guilty of robbery.
The lower court, disregarding his minority, imposed an indeterminate penalty ranging from 4 years, 2 months and 1 day of prision correccional to 8 years of prision mayor.
Additionally, a joint and several indemnity of P85.00 was ordered against him and the co-accused for the injured party.

The case involved the application of Article 68 of the RPC, which provides for a reduced penalty for offenders under eighteen years of age under specified circumstances.
Republic Act No. 47 amended Article 80 of the RPC by reducing the threshold age for committing a minor to a charitable or benevolent institution from 18 to 16.
The controversy arose over whether this amendment implicitly altered the privileges conferred by Article 68, paragraph 2, such that minors between 16 and 18 would no longer enjoy the mitigating circumstance.

The Solicitor General argued that the amendment to Article 80 by Republic Act No. 47 should be read as also amending Article 68, thereby depriving minors aged 16 to 18 of the privilege of a reduced penalty.
In response, the court emphasized established rules of statutory construction, asserting that:

All parts of a statute must be harmonized so that no section is rendered meaningless.
An amendment is presumed to be integrated into the original statute so that unchanged portions continue to have their former force.

The court noted that Article 68 is independent and self-sufficient in granting a reduced penalty and does not automatically lose its effect with the amendment of Article 80.

The court reviewed the legislative intent behind the amendment, noting that there was no explicit indication by Congress to abrogate or modify the mitigating provision of Article 68.
It reiterated the well-established rule that penal laws must be strictly construed against the state, thus favoring the accused in any doubt regarding the interpretation of the law.
The analysis included a discussion on the distinct spheres of application of Articles 68 and 80:

Article 68, addressing the imposition of a penalty, applies when a minor is sentenced after having been transferred from the custody of a reformatory institution.
Article 80, on the other hand, deals exclusively with the initial treatment and custody of minors.

Whether the appellant, being 17 years old at the time of his offense, was entitled to the privileged mitigating circumstance under Article 68, paragraph 2, of the Revised Penal Code.
Whether the amendment brought by Republic Act No. 47 to Article 80, by lowering the age threshold for court-committed custody, implicitly affects the application of Article 68 regarding the reduction of penalty for minor offenders.