People of the Philippines vs Francisco Larrañaga
January 31, 2006
Minority as a Defense
Larrañaga et al were convicted of kidnapping and serious illegal detention with homicide and rape on February 3, 2004; and for serious illegal detention. The first crime is punishable by death and the second is punishable by reclusion perpetua. One of the co-accused, James Andrew Uy, alleged that on July 16, 1997, the date of the commission of the crime, he was only 17 years old and 262 days old. To prove his claim, Uy presented his birth certificate duly certified by the City Civil Registrar and the National Statistics Office.
ISSUE: Whether or not Uy is entitled a mitigating circumstance due to minority?
HELD: Yes. Uy was able to prove his claim hence he is entitled to a mitigating circumstance in both crimes charged against him. This is pursuant to Article 68 and 80 of the Revised Penal Code, which provides that persons below 18 years of age are entitled to a penalty one degree lower than that imposed by law.