Case Summary (G.R. No. 120098)
Applicable Law
This case revolves around Republic Act No. 8368, which repealed Presidential Decree No. 772, also known as the Anti-Squatting Law. The repeal of this decree is pivotal to the arguments regarding the extinguishment of both criminal and civil liabilities.
Case Background
The petitioners were convicted by the MTC-Quezon City for violation of the Anti-Squatting Law. They appealed to the RTC, which affirmed their conviction. Following this, Republic Act No. 8368 was enacted, repealing the previous law. The RTC, in January 1998, determined that while the criminal convictions were extinguished due to the law's repeal, the civil liabilities, including the removal of the petitioners' illegally built structures, remained intact.
Court of Appeals Rulings
The Court of Appeals upheld the RTC's ruling, maintaining that only the criminal liability had been extinguished while the civil liabilities against the petitioners persisted. This interpretation prompted the petitioners to escalate the matter to the Supreme Court, claiming that the repeal of the law eliminated all liabilities associated with it.
Petitioners' Arguments
The petitioners argue that the complete repeal of P.D. 772 by R.A. 8368 absolves them of any form of liability. They contend that since the act of squatting is no longer classified as a crime, neither can there exist any civil liabilities stemming from it. Furthermore, they highlight errors in legal interpretations that took the position that civil liability could be separable from the criminal aspect.
Respondent's Position
I.C. Construction, Inc. asserted that the ruling made by the lower courts regarding civil liability was correct, emphasizing that the provisions of Article 113 of the Revised Penal Code support the notion that civil liability persists unless expressly extinguished, which they argued had not occurred. They also indicated that the land’s title was adjudicated in their favor, reinforcing their claim of civil liability against the petitioners.
Office of the Solicitor General's Stance
In support of the petitioners, the Office of the Solicitor General concurred that both criminal and civil liabilities were extinguished by the enactment of R.A. 8368. Their recommendation was for the Supreme Court to reverse the lower court rulings that maintained any civil liabilities against the petitioners.
Interpretation of R.A. 8368
The Supreme Court noted that R.A. 8368 explicitly provides that all pending cases related to the actions penalized by P.D. 772 shall be dismissed effective upon the law's enactment. The unconditional repeal of the Anti-Squatting Law implies that the offense of squatting ceased to exist legally, thus erasing both criminal and civil liabilities associated with it.
Legislative Intent
The Court further acknowledged that R.
...continue readingCase Syllabus (G.R. No. 120098)
Case Identifier and Background
- Petitioners: Prescilla Tuates and Andres De La Paz
- Respondents: Hon. Lucas P. Bersamin, as Presiding Judge, Branch 96, RTC Quezon City, People of the Philippines, and I.C. Construction, Inc.
- G.R. No. 138962, decided on October 4, 2002
- Jurisprudence: 439 Phil. 289; 100 OG No. 48, 8049 (November 29, 2004)
- Legal context: Petition for review on certiorari under Rule 45 of the Rules of Court.
Procedural History
- Petitioners were convicted by the Metropolitan Trial Court (MTC) of Quezon City for violating Presidential Decree No. 772 (Anti-Squatting Law).
- The Regional Trial Court (RTC) of Quezon City affirmed the conviction on September 10, 1997.
- Following the enactment of Republic Act No. 8368, which repealed P.D. No. 772, the RTC ruled on January 28, 1998, that while the criminal convictions were extinguished, the civil aspects remained executory.
- The Court of Appeals upheld the RTC's order in its decision dated April 30, 1999, and denied a motion for reconsideration on June 9, 1999.
Issues Raised by Petitioners
- Petitioners contended that the repeal of P.D. No. 772 absolved them of both criminal and civil liabilities.
- They argued that the RTC erred in ruling that the civil aspects remained executory despite the repeal.
- Petitioners claimed the Court of Appeals grossly ignored applicable laws and jurisprudence in affirming the RTC's decisi