Facts
XXX265302, a child in conflict with the law, was charged with rape.
The RTC held that XXX265302’s denial cannot prevail over AAA265302’s straightforward and candid testimony. The court considered XXX265302’s minority as a special mitigating circumstance, and following Section 38 of Republic Act No. 9344, it suspended the sentence.
A few months after the conviction, the RTC issued an arrest warrant, and the accused—who was then an adult—was detained at the New Bilibid Prison and later transferred to the Davao Prison and Penal Farm. By the time the case reached the Supreme Court, the accused was 25 years old.
ISSUE: Whether an offender who was a minor at the time of the crime is still entitled to a suspended sentence, even if they are already over the age of 21 at the time of judgment or appeal.
Ruling
The Supreme Court affirmed the conviction but ordered the suspension of the sentence, despite the accused being 25 years old.
The Court clarified that the most important factor is the age at the time the crime was committed, not the age at the time of the judgment. The law’s intent is restorative and rehabilitative, aiming to give child offenders a chance to become productive members of society.
Under Section 40 of RA 9344, a court can extend a suspended sentence until the child reaches 21. However, the SC cited its previous ruling in People v. Jacinto to emphasize that sentences can be suspended even beyond age 21 if it serves the best interest of the offender’s rehabilitation.
The Court ordered the accused to be removed from the national penitentiary (New Bilibid Prison) and remanded the case to the RTC. The RTC was instructed to confine him in an agricultural camp or other training facility, as provided under Section 51 of RA 9344, instead of a regular prison.