Centeno v. Villalon-Pornillos, GR No.
113092, September 1, 1994 - PENAL LAWS
ARE TO BE CONSTRUED STRICTLY AGAINST THE STATE AND LIBERALLY IN
FAVOR OF THE ACCUSED
DOCTRINE:
● 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. They are not to be strained by construction to spell out a new
offense, enlarge the field of crime or multiply felonies. Hence, in the interpretation
of a penal statute, the tendency is to subject it to careful scrutiny and to construe
it with such strictness as to safeguard the rights of the accused.
FACTS:
● A civic organization known as the Samahang Katandaan ng Nayon ng Tikay
launched a fund drive for the purpose of renovating the chapel of Barrio Tikay,
Malolos, Bulacan.
● Martin Centeno, the chairman of the group, together with Vicente Yco,
approached Judge Adoracion G. Angeles, a resident of Tikay, and solicited from
her a contribution of P1,500.00.
● It is admitted that the solicitation was made without a permit from the Department
of Social Welfare and Development.
● Based on the complaint filed by Judge Angeles, an information was filed against
Martin Centeno for violation of Presidential Decree No. 1564, or the Solicitation
Permit Law, before the Municipal Trial Court of Malolos.
PROCEDURAL FACTS:
● Centeno filed a Motion to Quash arguing that there was no offense since P.D. No.
1564 only covers solicitations for public and welfare purposes and not religious
purposes.
● The MTC denied the Motion to Quash, and subsequently denied the Motion for
Reconsideration.
● The MTC rendered its Decision finding Centeno and his co-accused guilty of
violating P.D. No. 1564 and sentenced them to suffer the fine of P200. The MTC
however recommended pardon for Centeno and his co-accused, finding that they
acted in good faith and should not be criminally liable.
● Centeno filed an appeal to the Regional Trial Court of Malolos. Yco withdrew his
appeal.
● Respondent Judge Villalon-Pornillos affirmed the decision of the MTC but
increased the penalty of Cento by sentencing him to suffer imprisonment of 6
months and a fine of P1,000. The RTC said that this is because of the perversity
of the act committed which caused damage and prejudice to Judge Angeles.
● The RTC denied the Motion for Reconsideration of Centeno
● Hence the instant appeal to the Supreme Court of Centeno.
ISSUE:
● Whether or not the phrase “charitable purposes” should be construed in its
broadest sense so as to include a religious purpose.
● Whether or not solicitations for religious purposes are within the ambit of P.D. No.
1564.
RULING:
● The SC ruled REVERSING the Decision of the RTC and ACQUITTING Martin
Centeno of violating P.D. No. 1564, otherwise known as the Solicitation Permit
Law.
● The SC held that “charitable purpose” is capable of different significations outside
of “religious purpose” it may not be construed in its broadest sense so as to
include a religious purpose since Presidential Decree No. 1564 is a penal law, it
cannot be given such a broad application since it would be prejudicial to
petitioners.
● The SC held that to subsume the “religious” purpose of the solicitation within the
concept of “charitable” purpose which under Presidential Decree No. 1564
requires a prior permit from the Department of Social Services and Development;
under pain of penal liability in its absence would be prejudicial to the petitioner.
● 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. They are not to be strained by construction to spell out a new
offense, enlarge the field of crime or multiply felonies. Hence, in the interpretation
of a penal statute, the tendency is to subject it to careful scrutiny and to construe
it with such strictness as to safeguard the rights of the accused.
