G.R. No. L-38674 - People vs. Regular

Petitioners Prescilla Tuates and Andres de la Paz were charged with the violation of Presidential Decree No. 772 (the Anti-Squatting Law).
They were convicted by the Metropolitan Trial Court (MTC) of Quezon City (Branch 38) for squatting offenses.

Petitioners appealed to the Regional Trial Court (RTC) of Quezon City (Branch 96).
The RTC affirmed their conviction in its decision dated September 10, 1997.

While the petitioners’ motion for reconsideration was pending in the RTC, Republic Act No. 8368—the Anti-Squatting Law Repeal Act of 1997—was enacted.
RA 8368 explicitly repealed PD No. 772, thereby decriminalizing the act of squatting.

In its January 28, 1998 Order, the RTC ruled that the criminal convictions of petitioners were extinguished by RA 8368.
However, the RTC held that the civil aspect, involving the removal of the illegally constructed house and improvements, would remain executory against petitioners.

On petition for review, the Court of Appeals (CA) sustained the RTC’s ruling in its Decision dated April 30, 1999.
Thereafter, the CA denied the petitioners’ motion for reconsideration in its Resolution dated June 9, 1999.

Petitioners contended that the repeal of PD 772 by RA 8368 should extinguish both criminal and civil liabilities.
They argued that without a crime, there can be no corresponding civil liability.
Petitioners further asserted that the CA erred in ignoring applicable laws and jurisprudence concerning the repeal’s effect.
Private respondents maintained that only criminal liability was extinguished, citing Article 113 of the Revised Penal Code to justify the remaining civil liability.
The Solicitor General, representing public respondents, aligned with petitioners, arguing for the total extinguishment of liabilities.

RA 8368 expressly repeals PD 772 (Section 2) and mandates the dismissal of all pending cases under it (Section 3).
Senate records and legislative intent demonstrate that the law was intended to decriminalize squatting while protecting the property rights of legitimate landowners.
The lawmakers envisioned the repeal as part of a broader anti-poverty initiative aimed at reforming urban housing and land policies.

Whether the enactment of RA 8368, which unconditionally repeals PD 772, terminates both the criminal and civil liabilities arising from the offense of squatting.

Does the repeal of a penal law inherently extinguish the derivative civil liability?
Is it correct to hold that the civil aspect, related to the removal of illegal structures, remains executable despite the repeal?

Whether the RTC and the CA erred in their interpretation of RA 8368 by ruling that the civil liability persists even after the repeal of PD 772.

Did the lower courts disregard or misinterpret the explicit provisions of RA 8368?
Was there a failure to properly apply legal precedents that support the comprehensive effect of a full repeal?

Whether the appellate courts erred in their procedural posture or substantive analysis by sustaining a decision that bifurcates criminal and civil liabilities under a law that unequivocally decriminalizes squatting.