Tuates v. Bersamin
REITERATIONFacts
The Antecedents: Petitioners Prescilla Tuates and Andres de la Paz were convicted by the Metropolitan Trial Court (MTC) of Quezon City for Violation of Presidential Decree (P.D.) No. 772, the Anti-Squatting Law. They appealed to the Regional Trial Court (RTC) of Quezon City, which affirmed their conviction. Procedural History: While petitioners' motion for reconsideration was pending before the RTC, Republic Act (R.A.) No. 8368, which repealed P.D. No. 772, was enacted. The RTC, in an Order dated January 28, 1998, ruled that only the criminal convictions were extinguished, but the civil aspect, specifically the removal of their illegally constructed house and improvements, remained executory. The Court of Appeals (CA) sustained the RTC's ruling in its Decision dated April 30, 1999, and denied petitioners' motion for reconsideration in a Resolution dated June 9, 1999. The Petition: Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the decisions of the CA and RTC. They argued that the repeal of P.D. No. 772 by R.A. No. 8368 absolved them of both criminal and civil liability.
Issue(s)
Whether the repeal of Presidential Decree No. 772 by Republic Act No. 8368 extinguishes both the criminal and civil liability of the petitioners. Whether the Court of Appeals erred in holding that the civil aspect of the judgment shall remain executory against the accused despite the repeal of the penal law.
Ruling
The petition is meritorious. The Supreme Court reversed and set aside the Decision of the Court of Appeals and modified the decisions of the RTC and MTC to the effect that the dismissal of the criminal cases shall include the dismissal of the civil aspects thereof.
Ratio Decidendi
On the extinction of criminal and civil liability: The Court held that the repeal of P.D. No. 772 by R.A. No. 8368 was explicit, categorical, definite, and absolute. This unqualified repeal had the effect of obliterating the offense of squatting, rendering what was previously penalized as illegal, now legal. Consequently, the Court declared that the absolute repeal of a penal law extinguishes both criminal and civil liabilities arising from the offense. Section 3 of R.A. No. 8368 explicitly states that "All pending cases under the provisions of Presidential Decree No. 772 shall be dismissed upon the effectivity of this Act." This clearly indicated the legislative intent to decriminalize squatting. The Court emphasized that where an act or omission is no longer a crime, no person can be held liable for it, and thus, civil liability ex delicto is out of the question. The Court cited its implicit recognition of this principle in People v. Leachon, Jr., where a petition was dismissed without qualification due to the enactment of R.A. No. 8368. On the executory nature of the civil aspect: The Court ruled that since the criminal liability was extinguished by the repeal of P.D. No. 772, the civil liability, which is rooted in the criminal offense, was also extinguished. Article 113 of the Revised Penal Code, which obliges an offender to satisfy civil liability notwithstanding the extinction of criminal liability (except as provided in Article 112), was not applicable here because the very basis of the civil liability, the crime itself, no longer existed. Therefore, the RTC and CA erred in holding that the civil aspect remained executory. The Court clarified that while R.A. No. 8368 decriminalized squatting, it did not grant an unbridled license to illegally occupy lands, and recourse could still be had under other existing laws for violations of property rights.
Main Doctrine
The unqualified repeal of a penal law, such as Presidential Decree No. 772 by Republic Act No. 8368, extinguishes both the criminal and civil liabilities arising from the offense, and all pending cases related thereto shall be dismissed.