VALCESAR ESTIOCA VS PEOPLE OF THE PHILIPPINES

GR 173876 (JUNE 27, 2008)

FACTS
A number of persons were accused of conspiring and robbing an
elementary school. One of which is BONIAO who was 14 years old at
the time of the commission of the crime. They were found guilty by
the lower court. When the case was appealed to the CA, RA 9344
took effect and BONIAO was acquitted since he was a minor at the
time of the crime but without prejudice to his civil liability. Custody
was given to his parents.

ISSUE
Whether RA 9344 can retroact to BONIAO’s case.

HELD
Yes, the reckoning point in considering minority is the time of the
commission of the crime. In this case, BONIAO is 14 years old and
so he is exempted from criminal liability without prejudice to his civil 1
liability. Art. 22 of the Revised Penal Code provides that Penal Laws
may be given retroactive effect if they are in favor of the accused.