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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.

AT A GLANCE:

In Intestate Estate of Carungcong v. People of the Philippines and William Sato, G.R. No. 181409, February 11, 2010, the Supreme Court held that the fundamental principle in applying and in interpreting criminal laws is to resolve all doubts in favor of the accused. In dubio pro reo. When in doubt, rule for the accused. This is in consonance with the constitutional guarantee that the accused shall be presumed innocent unless and until his guilt is established beyond reasonable doubt.

In criminal law, one of the most fundamental safeguards afforded to an accused is the principle of in dubio pro reo, which means “when in doubt, for the accused.” This doctrine reflects the constitutional guarantee that an accused is presumed innocent until proven guilty beyond reasonable doubt.

This principle is anchored on the Bill of Rights under Article III of the 1987 Constitution of the Philippines, particularly on the rights of the accused.

Section 14(2), Article III provides that:

“In all criminal prosecutions, the accused shall be presumed innocent until the contrary is proved, xxx.”

Consistent with this constitutional mandate, the Supreme Court has held that:

The fundamental principle in applying and in interpreting criminal laws is to resolve all doubts in favor of the accused. In dubio pro reo. When in doubt, rule for the accused. This is in consonance with the constitutional guarantee that the accused shall be presumed innocent unless and until his guilt is established beyond reasonable doubt. (Intestate Estate of Carungcong v. People of the Philippines and William Sato, G.R. No. 181409, February 11, 2010)

Closely related to this principle is the rule of lenity. 

As emphasized in People v. Yap, G.R. No. 255087, October 4, 2023:

“Intimately related to the in dubio pro reo  principle is the rule of lenity.  The rule applies when the court is faced with two possible interpretations of a penal statute,  one that is prejudicial to the accused and another that is favorable to him or her.  The rule calls for the adoption of an interpretation which is more lenient to the accused. For it is a well-entrenched rule that penal laws are to be construed strictly against the State and liberally in favor of the accused.  They are not to be extended or enlarged by implications,  intendments,  analogies,  or equitable considerations.  If the statute is ambiguous and admits of two reasonable but contradictory constructions,  that which operates in favor of a party accused under its provisions is to be preferred.”

Thus, the rule of lenity applies when the court is faced with two possible interpretations of a penal statute, one prejudicial to the accused and another favorable. In such cases, the interpretation that is more lenient to the accused must be adopted.

Accordingly, ambiguity in penal statutes cannot be used to expand criminal liability and must be resolved in favor of the accused.

In the same vein, jurisprudence further provides that when a criminal act is penalized by distinct statutes, the penalty most favorable to the accused shall be applied:

“It is a fundamental principle in applying and interpreting criminal laws to resolve all doubts in favor of the accused or the so-called in dubio pro reo. When in doubt, rule for the accused because of the constitutional presumption of his innocence until the contrary is proven beyond reasonable doubt. Accordingly, when a criminal act is penalized by distinct criminal statutes, that penalty which is favorable to the accused shall be applied.” (People v. Altubar, G.R. No. 207089 (Notice), February 18, 2015)

Ultimately, the in dubio pro reo principle serves as a safeguard against wrongful conviction. It ensures that no person is deprived of liberty on the basis of uncertainty, ambiguity, or doubtful interpretation of the law.

In the administration of criminal justice, it is not enough that the accused may be guilty. The law requires that guilt be established with proof beyond reasonable doubt.

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Alburo Alburo and Associates Law Offices specializes in business law and labor law consulting. For inquiries regarding legal services, you may reach us at info@alburolaw.com, or dial us at (02)7745-4391/ 09175772207/ 09778050020.

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