Ilon vs. People

Article 64 of the Revised Penal Code, which provides the rules on the application of modifying circumstances, applies to reckless imprudence resulting in homicide committed with violation of the Automobile Law under Article 365, paragraph 6, subparagraph 2; the first five paragraphs of Article 365, including paragraph 5's directive to disregard Article 64, do not apply to paragraph 6, subparagraph 2. Failure to lend aid on the spot is a qualifying circumstance that must be alleged in the Information before it can increase the penalty.

Petitioner Noli Z. Ilon was employed as the family driver of a Honda Civic owned by Rodelio Malinao, Sr. The victim, Lee de la Cruz, drove a trisikad. The case concerns the interplay between Article 365 of the Revised Penal Code, which penalizes reckless imprudence and negligence, and Article 64, which governs the application of modifying circumstances; Article 365, paragraph 5 ordinarily directs courts to disregard Article 64, while paragraph 6, subparagraph 2 prescribes prision correccional in its medium and maximum periods when death is caused by imprudence or negligence with violation of the Automobile Law. The Revised Penal Code's Article 103 on subsidiary civil liability of employers and the Indeterminate Sentence Law also frame the penalty and civil liability issues.

On the evening of October 31, 2003, Lee de la Cruz parked a trisikad to drop off his passenger and sacks of rice at the side of Circumferential Road, Barangay Banago, Bacolod City, close to the Bangga Pepsi plant near the intersection between Circumferential Road and Lacson Street. Noli Z. Ilon was driving a Honda Civic owned by Jose Rodelio Malinao, Sr. According to the prosecution, Ilon was running fast close to the intersection and bumped the parked trisikad. Lee was thrown on top of the motor vehicle, fell on the road, and was ran over by Ilon, who then hurriedly left the place without helping Lee. Lee was brought to Corazon Locsin Montelibano Memorial Hospital but was declared dead on November 1, 2003. At around 8:00 a.m. of even date, Ilon surrendered to the Office of the Investigation Section, Traffic Division of the Bacolod City Police Office, reported the incident, and admitted having been the driver of the Honda Civic that bumped Lee.

In his defense, Ilon claimed that on October 31, 2003, he was driving the Honda Civic from Circumferential Road to Lacson Street on his way home to Talisay City after doing an errand for the wife of his employer, Rodelio Malinao, Sr. Upon reaching the corner near the Bangga Pepsi plant, he alleged that he was merely an arms-length away when he noticed the parked trisikad, which he tried to avoid. He still bumped the trisikad because the latter turned and moved to the center of the road when the passenger alighted. He described the area as dark because there were no lights around the intersection. Ilon alleged that he attempted to help Lee but did not pursue it because he was being stoned by bystanders. During cross-examination, Ilon stated that he was about eight arms' length or 30 feet away from the intersection when he first saw the trisikad driven by Lee, which was around three arms' length away from the intersection. He stated that he was driving at a normal speed of 40kph and that he tried to avoid the trisikad, but nonetheless still bumped it because the trisikad moved downward. He admitted that he did not stop or slow down despite the trisikad stopping because his motor vehicle was running too fast, and he even increased the speed of his motor vehicle upon reaching the intersection; it was only then that he noticed that the trisikad was in front of him.

The defense also presented Marissa Malinao, who testified that Ilon was their family driver of the Honda Civic owned by Rodelio. After the accident, she alleged that she advised Ilon to report the incident the following day while the latter argued that the accident was not his fault. The defense further presented Rommel Gimongala, another trisikad driver, who testified that he saw a white car which tried to avoid the trisikad of Lee, but the same car eventually hit the trisikad and its driver.

The lower courts found that all the elements of Article 365 of the Revised Penal Code were proven by the prosecution beyond reasonable doubt. The MTCC relied on the testimonies of the prosecution and the admissions of Ilon, particularly his admission that he did not take any form of precaution while driving in an intersection and even increased his speed, which caused his motor vehicle to bump into the trisikad and caused Lee's death. It found untenable Ilon's argument of Lee's contributory negligence, opining that the same does not apply in criminal cases arising from reckless imprudence. The RTC agreed that Ilon could not invoke contributory negligence and that there was an inexcusable lack of precaution on his part based on his own admissions during cross-examination that he did not slow down and even sped up when approaching the intersection. The CA likewise held that the prosecution established that the motor vehicle driven by Ilon was running at a fast speed and hit the rear of the trisikad, causing Lee to be thrown off into the air and land on the hood of the car, and considered Ilon's admissions that he did not slow down and instead increased his speed while approaching an intersection.

• Accident Not His Fault / Contributory Negligence: Ilon claimed that the accident was not his fault; he alleged that Lee's trisikad turned and moved to the center of the road when the passenger alighted, that the area was dark, and that he tried to avoid the trisikad. He argued that Lee's contributory negligence should be considered.
• Voluntary Surrender: Ilon invoked the circumstance of voluntary surrender to mitigate his criminal liability, noting that he surrendered to the authorities and admitted having been the driver of the Honda Civic that bumped Lee.

• Conviction for Reckless Imprudence Resulting in Homicide: Whether the CA correctly upheld Ilon's conviction for reckless imprudence resulting in homicide under Article 365 of the Revised Penal Code.
• Contributory Negligence: Whether Lee's alleged contributory negligence constitutes a defense to Ilon's criminal liability or a mitigating circumstance.
• Failure to Render Assistance: Whether the CA correctly increased the penalty based on Ilon's failure to render assistance despite such circumstance not being alleged in the Information.
• Applicability of Article 64: Whether Article 64 of the Revised Penal Code, on modifying circumstances, applies to reckless imprudence resulting in homicide with violation of the Automobile Law under Article 365, paragraph 6, subparagraph 2.
• Voluntary Surrender: Whether Ilon's voluntary surrender may be appreciated as a mitigating circumstance.
• Penalty: Whether the penalty imposed by the CA should be modified.
• Civil Liability and Subsidiary Liability: Whether the damages and the finding of Rodelio's subsidiary liability are proper.

• Conviction for Reckless Imprudence Resulting in Homicide: Yes. The conviction was affirmed; the prosecution established inexcusable lack of precaution based on Ilon's admissions and the factual findings of the lower courts.
• Contributory Negligence: No. Contributory negligence is not a defense in reckless imprudence; at most it may be considered in the award of damages, and here it was not factually proven.
• Failure to Render Assistance: No. Failure to lend aid is a qualifying circumstance that must be alleged in the Information; it was not alleged, so it cannot increase the penalty.
• Applicability of Article 64: Yes. Article 64 applies to Article 365, paragraph 6, subparagraph 2; paragraph 6's non-applicability clause refers only to the preceding paragraphs 1 to 5.
• Voluntary Surrender: Yes. Ilon voluntarily surrendered and admitted being the driver; voluntary surrender is a mitigating circumstance.
• Penalty: Modified. Ilon was sentenced to an indeterminate penalty of 4 months and 1 day of arresto mayor as minimum to 2 years, 4 months, and 1 day of prision correccional as maximum.
• Civil Liability and Subsidiary Liability: The damages as modified by the RTC remain undisturbed, but the conditional finding of Rodelio's subsidiary liability was erroneous because Ilon's insolvency had not yet been proven.

• Conviction for Reckless Imprudence Resulting in Homicide: Article 365 of the Revised Penal Code defines reckless imprudence as a voluntary act done without malice, from which an immediate personal harm, injury, or material damage results by reason of an inexcusable lack of precaution or advertence. Its elements are: (1) the offender does or fails to do an act; (2) the doing or failure to do the act is voluntary; (3) it is without malice; (4) material damage results from the reckless imprudence; and (5) there is inexcusable lack of precaution on the part of the offender, taking into consideration their employment or occupation, degree of intelligence, physical condition, and other circumstances regarding persons, time, and place. The courts a quo consistently and correctly held that there was an inexcusable lack of precaution on the part of Ilon based on his admissions and the factual circumstances. Ilon himself admitted that he failed to slow down despite knowing he was approaching an intersection and that the area was dark; worse, he sped up, resulting in the accident that caused Lee's death. Caminos, Jr. vs. People held that a motorist is expected to exercise ordinary care and drive at a reasonable rate of speed commensurate with all conditions encountered, especially when close to an intersection. The trial court's findings, affirmed by the appellate court, are binding absent exceptional circumstances.

• Contributory Negligence: Caminos, Jr. vs. People held that the negligence of the person injured or who was the driver of the motor vehicle with which the accused's vehicle collided does not constitute a defense in the crime of reckless imprudence; such negligence shall only be considered in the award of damages. Contributory negligence is analogous to sufficient provocation and, if factually proven, may be considered a mitigating circumstance under Article 13(10) of the Revised Penal Code in relation to Article 13(4), because the injury caused to the offended party would not have occurred if not for the offended party's failure to conform with the standard required of him. However, the Court found untenable Ilon's assertion that Lee was guilty of contributory negligence. As uniformly found by the courts a quo, no contributory negligence could be ascribed to Lee, considering that he simply alighted from the trisikad and it was Ilon's lack of precaution of speedily driving which caused the accident. Thus, Ilon was not entitled to the mitigating circumstance of contributory negligence.

• Failure to Render Assistance: Article 365, paragraph 9 of the Revised Penal Code prescribes the penalty next higher in degree to those provided for in the article upon the offender who fails to lend on the spot to the injured parties such help as may be in his hands to give. This failure to help on the spot is a qualifying circumstance, which operates to increase the imposable penalty by a degree, and as such must be alleged in the Information. Ibabao vs. People ruled that the increased penalty is inapplicable if the failure to give aid to the injured on the spot has not been alleged in the Information, because the failure to render assistance constitutes a qualifying circumstance that must be alleged to apprise the defendant of the charge. The Court has consistently held that for qualifying aggravating circumstances to be appreciated, they must be alleged in the Information and consequently proven during trial, in line with the constitutional right of an accused to be informed of the nature and cause of the accusation. A plain reading of the Information shows that it is bereft of any factual averment stating that Ilon failed to render assistance on Lee. Thus, even if this fact was proven during trial, the Court was constrained to disregard this circumstance.

• Applicability of Article 64: Article 365, paragraph 5 of the Revised Penal Code states that in the imposition of the penalties under Article 365, the courts shall exercise their sound discretion, without regard to the rules prescribed in Article 64. Article 365, paragraph 6 states that the provisions contained in the article shall not be applicable: (1) when the penalty provided for the offense is equal to or lower than those provided in the first two paragraphs, and (2) when, by imprudence or negligence and with violation of the Automobile Law, the death of a person shall be caused, in which case the defendant shall be punished by prision correccional in its medium and maximum periods. The Court identified two views. The first view, held in Apigo, Agito, Medroso, and Delos Santos, is that modifying circumstances are not applicable to all acts committed under Article 365, including paragraph 6, subparagraph 2, based on paragraph 5. The second view, held in Ibabao, is that modifying circumstances under Article 64 may be applied to acts committed under Article 365, paragraph 6, subparagraph 2, because the first five paragraphs of Article 365 do not apply to paragraph 6 based on its clause stating that the provisions contained in the article shall not be applicable. The Court adopted the second view under the verba legis rule or plain meaning rule. A cursory reading of Article 365, paragraph 6 shows that the non-applicability clause clearly refers to the preceding paragraphs, including paragraph 5. Thus, paragraph 6 should be considered as the exception to the applicability of the preceding provisions under Article 365, including paragraph 5. The history and development of Article 365 and the penalty for reckless imprudence resulting in homicide committed while using a motor vehicle supported the second view. The Court reconsidered the doctrine espoused by Agito and similar cases and held that Article 64 applies to the commission of acts covered by Article 365, paragraph 6, specifically those falling within subparagraph 2. The exception in Article 365, paragraph 6 only relates to the paragraphs preceding it; the succeeding paragraphs, including the last paragraph on failure to lend aid, are still applicable to all crimes falling under Article 365 where there is an injured party involved, regardless of whether they fall under paragraphs 1 to 5 or paragraph 6.

• Voluntary Surrender: People vs. Doca reiterated that voluntary surrender may be appreciated to mitigate the imposable penalty when the following requisites are present: (1) the accused has not been actually arrested; (2) the accused surrenders himself to a person in authority or the latter's agent; and (3) the surrender is voluntary. The mitigating circumstance is based on the spontaneity and the intent of the accused to give himself up and submit himself to the authorities, either because he acknowledges his guilt or he wishes to save the authorities the trouble and expense that may be incurred for his search and capture. The records show that at around 8:00 a.m. of the same day of the commission of the crime, Ilon surrendered to the Office of the Investigation Section, Traffic Division of the Bacolod City Police Office. There, he reported the incident and admitted having been the driver of the Honda Civic that bumped Lee. These circumstances led the Court to conclude that Ilon had the intent to voluntarily surrender to the authorities, and thus the penalty should be adjusted accordingly with voluntary surrender as a mitigating circumstance.

• Penalty: The prescribed penalty under Article 365, paragraph 6, subparagraph 2 of the Revised Penal Code is prision correccional in its medium and maximum periods, i.e., two years, four months, and one day to six years. Applying the Indeterminate Sentence Law and taking into consideration the presence of the mitigating circumstance of voluntary surrender, the Court found it proper to sentence Ilon to suffer the penalty of imprisonment for an indeterminate period of four months and one day of arresto mayor as minimum to two years, four months, and one day of prision correccional as maximum. The CA erred in increasing the penalty based on failure to render assistance because that qualifying circumstance was not alleged in the Information.

• Civil Liability and Subsidiary Liability: The award of damages, as modified by the RTC's Decision dated January 12, 2018, should remain undisturbed, considering that Lee's heirs are not impleaded in the present case. Ilon was ordered to pay the total amount of PHP 629,883.45, broken down as follows: (a) PHP 547,200.00 for future support; (b) PHP 50,000.00 for civil indemnity for Lee's death; (c) PHP 50,000.00 for moral damages; and (d) PHP 22,683.45 for actual and compensatory damages as reduced by PHP 40,000.00 for Ilon having previously paid Lee's heirs. The total amount shall bear interest at the rate of 6% per annum from the date of finality of the ruling until full payment. The MTCC erred in making a conditional finding of Rodelio's subsidiary liability. Pangonorom vs. People held that the determination of an employer's subsidiary liability under Article 103 of the Revised Penal Code only arises when: (a) the conviction of the accused has become final and executory; and (b) after the writ of execution issued against the accused is returned unsatisfied because of their insolvency. It is only then that a subsidiary writ of execution can be issued against the employer after a hearing was set for that precise purpose. It is still too early to rule on Rodelio's subsidiary liability considering that Ilon's insolvency has yet to be proven.

• Reckless imprudence under Article 365 of the Revised Penal Code — Reckless imprudence consists of a voluntary act done without malice, from which an immediate personal harm, injury, or material damage results by reason of an inexcusable lack of precaution or advertence on the part of the person committing it. Its elements are:

  • (1) that the offender does or fails to do an act;
  • (2) that the doing or the failure to do that act is voluntary;
  • (3) that it be without malice;
  • (4) that material damage results from the reckless imprudence; and
  • (5) that there is inexcusable lack of precaution on the part of the offender, taking into consideration their employment or occupation, degree of intelligence, physical condition, and other circumstances regarding persons, time, and place. The Court applied this doctrine in affirming Ilon's conviction, finding that he failed to slow down and instead sped up while approaching a dark intersection, causing the death of Lee.

• Contributory negligence in reckless imprudence — The negligence of the person injured or who was the driver of the motor vehicle with which the accused's vehicle collided does not constitute a defense in the crime of reckless imprudence; instead, such negligence shall only be considered in the award of damages. Contributory negligence is analogous to sufficient provocation and, if factually proven, may be considered a mitigating circumstance under Article 13(10) of the Revised Penal Code in relation to Article 13(4). The Court applied this doctrine by rejecting Ilon's contributory negligence defense and finding no factual basis for the mitigating circumstance because Lee simply alighted from the trisikad.

• Failure to lend aid as a qualifying circumstance — The failure to lend aid on the spot to injured parties is a qualifying circumstance that operates to increase the imposable penalty by a degree and must be alleged in the Information. It cannot be appreciated if not alleged, even if proven during trial, because it violates the accused's constitutional right to be informed of the nature and cause of the accusation. The Court applied this doctrine by disregarding the CA's increase of Ilon's penalty based on failure to render assistance, as the Information did not allege such failure.

• Applicability of Article 64 to Article 365, paragraph 6, subparagraph 2 — Article 64 of the Revised Penal Code, which provides the rules on the application of modifying circumstances, applies to reckless imprudence resulting in homicide committed with violation of the Automobile Law under Article 365, paragraph 6, subparagraph 2. The non-applicability clause in Article 365, paragraph 6 refers only to the preceding paragraphs 1 to 5, including paragraph 5's directive to disregard Article 64. The Court adopted this second view under the verba legis rule, reconsidered the doctrine in Agito and similar cases, and applied Article 64 to appreciate Ilon's voluntary surrender.

• Voluntary surrender — Voluntary surrender may be appreciated to mitigate the imposable penalty when the following requisites are present: (1) the accused has not been actually arrested; (2) the accused surrenders himself to a person in authority or the latter's agent; and (3) the surrender is voluntary. It is based on the spontaneity and intent of the accused to give himself up and submit himself to the authorities, either because he acknowledges his guilt or he wishes to save the authorities the trouble and expense that may be incurred for his search and capture. The Court applied this doctrine because Ilon surrendered to the police at around 8:00 a.m. of the same day, reported the incident, and admitted being the driver.

• Employer's subsidiary liability under Article 103 — The determination of an employer's subsidiary liability under Article 103 of the Revised Penal Code only arises when: (a) the conviction of the accused has become final and executory; and (b) after the writ of execution issued against the accused is returned unsatisfied because of their insolvency. It is only then that a subsidiary writ of execution can be issued against the employer after a hearing was set for that precise purpose. The Court applied this doctrine by holding that the MTCC erred in conditionally finding Rodelio subsidiarily liable because Ilon's insolvency had not yet been proven.

• Verba legis or plain meaning rule — When the law is clear and unambiguous, the Court must apply it according to its clear language. The Court used this rule to adopt the second view that Article 64 applies to Article 365, paragraph 6, subparagraph 2, because the clause stating that the provisions contained in the article shall not be applicable clearly refers to the preceding paragraphs.

• Separation of powers and judicial legislation — The Court must abide by its constitutional function to interpret the law due to the principle of separation of powers, lest it be accused of judicial legislation. The determination of penalties is a policy matter belonging to the legislature. The Court applied this principle by noting the seeming incongruences in Article 365 but still interpreting the law as written, and by furnishing copies of the Decision to both Houses of Congress and the President pursuant to Article 5 of the Revised Penal Code.

• "Article 64 of the Revised Penal Code, which provides for the rules on the application of modifying circumstances, are applicable to the commission of acts covered by Article 365, paragraph 6 of the Revised Penal Code, specifically those falling within subparagraph 2." — This is the Court's central holding, reversing the prior doctrine in Agito and similar cases and allowing mitigating circumstances to apply to reckless imprudence resulting in homicide with violation of the Automobile Law.
• "The last paragraph on failure to fend aid on the spot necessarily applies to all situations envisioned in the said Article whenever there is an injured party." — This passage, quoted from Ibabao vs. People, clarifies that the qualifying circumstance of failure to lend aid applies to all crimes under Article 365, including paragraph 6, subparagraph 2, whenever there is an injured party.
• "Here, the records show that at around 8:00 a.m. of the same day of the commission of the crime, Ilon surrendered to the Office of the Investigation Section, Traffic Division of the Bacolod City Police Office. There, he reported the incident and admitted having been the driver of the Honda Civic that bumped Lee." — This passage supports the Court's finding of voluntary surrender as a mitigating circumstance.
• "the determination of an employer's subsidiary liability under Article 103 of the Revised Penal Code only arises when: (a) the conviction of the accused has become final and executory; and (b) after the writ of execution issued against the accused is returned unsatisfied because of their insolvency." — This passage states the requisites for employer's subsidiary liability, which the Court applied in holding that the MTCC's conditional finding was premature.

• Caminos, Jr. vs. People, 605 Phil. 422 (2009) — Controlling precedent on the standard of care required of motorists approaching an intersection and on contributory negligence not being a defense in reckless imprudence; followed by the Court.
• Ibabao vs. People, 217 Phil. 210 (1984) — Controlling precedent holding that failure to lend aid is a qualifying circumstance that must be alleged in the Information, and that the last paragraph of Article 365 applies to all situations envisioned in the article; followed and relied upon.
• United States vs. Apigo, 25 Phil. 631 (1913) — Prior precedent holding that courts may waive the ordinary rules on modifying circumstances in reckless imprudence cases; reconsidered and effectively abandoned by the Court's adoption of the second view.
• People vs. Agito, 103 Phil. 526 (1958) — Prior precedent holding that mitigating circumstances need not be considered in Article 365 cases; reconsidered and abandoned by the Court.
• People vs. Medroso, Jr., 159 Phil. 297 (1975) — Prior precedent following Agito on the non-application of Article 64 to Article 365; reconsidered and abandoned.
• People vs. Delos Santos, 407 Phil. 724 (2001) — Prior precedent following Agito and Medroso; reconsidered and abandoned.
• People vs. Doca, 865 Phil. 1077 (2019) — Cited for the requisites of voluntary surrender; followed by the Court.
• Pangonorom vs. People, 495 Phil. 195 (2005) — Controlling precedent on the requisites for employer's subsidiary liability under Article 103; followed by the Court.
• Barnes vs. Padilla, 500 Phil. 303 (2005) — Cited for the relaxation of procedural rules to serve substantial justice; relied upon by the Court in entertaining the late petition.
• People vs. Jugueta, 783 Phil. 806 (2016) — Cited by the RTC in modifying the civil indemnity; noted by the Court.
• Miranda vs. People, 846 Phil. 125 (2019) — Cited for the definition of sufficient provocation; used in the analogy to contributory negligence.
• Dela Cruz vs. Octaviano, 814 Phil. 891 (2017) — Cited for the definition of contributory negligence; used in the analogy to sufficient provocation.
• People vs. Arellano, 856 Phil. 500 (2019) — Cited for the rule that trial court findings affirmed by the appellate court are binding; relied upon by the Court.
• People vs. Solar, 858 Phil. 884 (2019) — Cited for the rule that qualifying aggravating circumstances must be alleged in the Information; relied upon by the Court.
• H. Villarica Pawnshop, Inc. vs. Social Security Commission, 824 Phil. 613 (2018) — Cited for the verba legis rule; relied upon by the Court.
• Curammeng vs. People, 799 Phil. 575 (2016) — Cited for the relaxation of procedural rules and the principle that an appeal in criminal cases opens the entire case for review; relied upon by the Court.
• Sumbilla vs. Matrix Finance Corporation, 762 Phil. 130 (2015) — Cited for the rule that a penalty in excess of the maximum authorized by law is void for want or excess of jurisdiction; relied upon by the Court in relaxing the rules.

• Article 365, Revised Penal Code — Defines reckless imprudence and simple imprudence and prescribes their penalties. Paragraph 5 directs courts to exercise sound discretion without regard to Article 64. Paragraph 6 provides exceptions to the applicability of the article, including subparagraph 2 on death caused by imprudence or negligence with violation of the Automobile Law. The last paragraph imposes the penalty next higher in degree for failure to lend aid on the spot. The Court applied these provisions in affirming the conviction, rejecting the penalty increase for failure to render assistance, and holding that Article 64 applies to paragraph 6, subparagraph 2.
• Article 64, Revised Penal Code — Provides the rules on the application of modifying circumstances. The Court held that it applies to reckless imprudence resulting in homicide with violation of the Automobile Law under Article 365, paragraph 6, subparagraph 2, and applied it to appreciate voluntary surrender.
• Article 13(10) and Article 13(4), Revised Penal Code — Article 13(10) allows analogous circumstances to paragraphs 1 to 9 of Article 13 to mitigate criminal liability; Article 13(4) refers to sufficient provocation or threat on the part of the offended party immediately preceding the act. The Court discussed that contributory negligence is analogous to sufficient provocation but found no factual basis for it.
• Article 103, Revised Penal Code — Establishes the subsidiary civil liability of employers for felonies committed by their servants or employees in the discharge of their duties. The Court held that the employer's subsidiary liability only arises after the conviction becomes final and executory and the writ of execution against the accused is returned unsatisfied due to insolvency.
• Article 5, Revised Penal Code — Provides the duty of the court in connection with acts which should be repressed but which are not covered by law, and in cases of executive penalties. The Court invoked this provision in ordering that copies of the Decision be furnished to the President of the Republic of the Philippines, the President of the Senate, and the Speaker of the House of Representatives.
• Rule 45, Section 2, in relation to Rule 124, Section 18, Rules of Court — Provides that a petition for review on certiorari shall be filed within 15 days from notice of the judgment appealed from or of the denial of petitioner's motion for reconsideration, and that the time of filing may be extended for a period not exceeding 30 days. The Court found Ilon's petition was filed out of time but relaxed the rules.
• Indeterminate Sentence Law, Act No. 4103, Section 1 — Provides the rules for imposing an indeterminate prison sentence. The Court applied it in fixing the minimum and maximum terms of Ilon's penalty.
• Republic Act No. 1790 — Amended Article 365 of the Revised Penal Code and is the present iteration of the article. The Court examined its history and language in resolving the applicability of Article 64.
• Republic Act No. 384 — Amended the fifth paragraph of Article 365 by changing the phrase "article 62" to "article sixty-four." The Court considered this amendment in its historical analysis.
• Act No. 3992, Republic Act No. 587, Republic Act No. 4136, and Batas Pambansa Blg. 398 — These laws amended the penalty for death caused by negligence or imprudence with the use of a motor vehicle. The Court reviewed their evolution to support the second view that Article 64 applies to Article 365, paragraph 6, subparagraph 2.

Gesmundo, C.J., Caguioa, Inting, Zalameda, Gaerlan, Rosario, J. Lopez, Dimaampao, Marquez, Singh, and Villanueva, JJ., concur. Leonen, SAJ., see concurring opinion. Hernando, J., on official business. Lazaro-Javier, J., on official business but left a concurring vote.

Leonen, SAJ. concurred with petitioner Noli Z. Ilon's conviction and seconded the ponencia's call to furnish the President and both Houses of Congress with copies of the Decision. He emphasized that the Revised Penal Code was enacted in 1930 during American colonial rule and remains the cornerstone of the criminal law system despite being almost a century old. He advocated for a new penal code that reflects present-day Philippine society, eliminates outdated and gender-skewed provisions, and updates fines and threshold figures to account for inflation and changing economic conditions. He noted that piecemeal amendments and numerous special penal laws have rendered the criminal law field vulnerable to inconsistencies and gaps, and that a unified penal code would ensure fairness, clarity, and orderly administration of justice.