Criminal Law

People of the Philippines vs Francisco Larrañaga

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G.R. Nos. 138874-75 – 421 SCRA 530 (2004); 463 SCRA 652 (2006) – Criminal Law – Book I – Mitigating Circumstances – Minority; Proof

In July 2005, the Supreme Court affirmed the conviction of Francisco Larrañaga and others, including one James Andrew Uy. Larrañaga et al were convicted of kidnapping and serious illegal detention with homicide and rape; and for serious illegal detention. The first crime is punishable by death and the second is punishable by reclusion perpetua. One of the co-accused, James Andrew Uy, alleged that on July 16, 1997, the date of the commission of the crime, he was only 17 years and 262 days old. However, the Supreme Court was not convinced of his minority because the copy of his Certificate of Live Birth attached to the record was not legible. Further, in the Formal Offer of Evidence, it was manifested by the defense counsel that James Andrew Uy was already 18 years old at the time of the alleged incident.

Nevertheless, the Supreme Court directed the Solicitor General to obtain a copy of Uy’s Certificate of Live Birth from the National Statistics Office. (Note: The Supreme Court in this case allowed the reception of evidence at this stage of the proceeding and despite the blunder during the offer of evidence. Normally, the Supreme Court is not a trier of facts.)

ISSUE: Whether or not Uy is entitled a mitigating circumstance due to minority?

HELD: Yes. Uy was able to prove his claim hence he is entitled to a mitigating circumstance in both crimes charged against him. This is pursuant to Articles 68 and 80 of the Revised Penal Code, which provide that persons below 18 years of age are entitled to a penalty one degree lower than that imposed by law.

Our legal system does not punish a youth as it would an adult, and it sees youthful misconduct as evidence of unreasoned or impaired judgment. Thus, in a myriad of cases, the Supreme Court applied the privileged mitigating circumstance of minority embodied in Article 68 of the Revised Penal Code — the rationale of which is to show mercy and some extent of leniency in favor of an accused who, by reason of his age, is presumed to have acted with less discernment.

Thus, the imposable penalty on James Andrew, by reason of his minority, is one degree lower than the statutory penalty. The penalty for the special complex crime of kidnapping and serious illegal detention with homicide and rape, being death, one degree lower therefrom is reclusion perpetua. On the other hand, the penalty for simple kidnapping and serious illegal detention is reclusion perpetua to death. One degree lower therefrom is reclusion temporal. There being no aggravating and mitigating circumstance, the penalty to be imposed on James Andrew is reclusion temporal in its medium period. Applying the Indeterminate Sentence Law, he should be sentenced to suffer the penalty of twelve (12) years of prision mayor in its maximum period, as minimum, to seventeen (17) years of reclusion temporal in its medium period, as maximum.

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Note: This case was so controversial that it resulted in the suspension of the imposition of the death penalty. This was dubbed as the Trial of the Century and many would say that the attention it received as well as the criticisms as to how the case was handled pressured the administration of then Gloria Arroyo to cause the prohibition of the death penalty (R.A. No. 9346, An Act Prohibiting the Imposition of Death Penalty in the Philippines)

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