Title
Penalty Amendment for Robbery with Rape
Law
Presidential Decree No. 767
Decision Date
Aug 15, 1975
Presidential Decree No. 767 amends the Revised Penal Code in the Philippines to rectify the disparity in penalties between rape committed with a deadly weapon or by two or more persons and robbery with rape, ensuring that the punishment for the latter is commensurate with its severity.

Law Summary

Reason for Amendment

  • The disparity resulted from the failure to increase penalties for robbery with rape following the enhancement of penalties for aggravated rape.
  • Recognition that robbery with rape is more serious than rape alone.
  • Need to align penalties for robbery with rape to those of aggravated rape for parity and proportionality.

Amendments to Article 294(2) of the Revised Penal Code

  • The penalty for robbery with the use of violence or intimidation is increased when accompanied by rape or intentional mutilation.
  • Standard penalty for robbery with rape or intentional mutilation: reclusion temporal in its medium period to reclusion perpetua.
  • If robbery with rape is committed with a deadly weapon or by two or more persons, the penalty is elevated to reclusion perpetua to death, matching the penalty for aggravated rape.

Scope and Application

  • Covers robbery involving violence or intimidation against a person.
  • Specifically addresses cases where rape or intentional mutilation occurs.
  • Also applies when, during robbery, physical injuries as defined under subdivision 1 of Article 263 are inflicted.

Penalty Provisions

  • Baseline penalty for robbery with violence: various terms of imprisonment.
  • Enhanced penalty for robbery with rape or intentional mutilation: medium period of reclusion temporal to reclusion perpetua.
  • Highest penalty for robbery with rape committed with deadly weapon or multiple perpetrators: reclusion perpetua to death.

Effective Date

  • The law took effect immediately upon its promulgation on August 15, 1975.

Legal Significance

  • Ensured proportionality and consistency in penalties for crimes involving sexual violence and robbery.
  • Reflected state policy to impose stricter penalties on more heinous crimes to serve justice and deterrence.
  • Clarified and strengthened the penal provisions for robbery cases complicated by rape or mutilation, addressing previous legal gaps.

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