People v. Rediolan Lazona y Tarlac G.R. No. 223688 November 13, 2019

Criminal Law; Amount for monetary award of damage for special complex crime

Facts:

Accused-appellant Rediolan Lazona y Tarlac failed to sufficiently show that the Court of Appeals committed reversible error in upholding his conviction for the crime of Robbery with Homicide.

Issue:

What is the monetary award for damages that should be issued?

Ruling:

Following People v Jugueta (783 Phil 806 [2016]) and A.M. No. 15-08-02-SC (Guidelines for the Proper Use of the Phrase ‘WIthout Eligibility for Parole” in Indivisible Penalties), the Supreme Court ruled that the monetary award of damages should be:

  • P100,000 as civil indemnity,
  • P100,000 as moral damages, and
  • P100,000 as exemplary damages.

Lastly, interest at the rate of 6% per annum is imposed on the damages awarded reckoned from the date of finality of the judgment until fully paid.

People v Jugueta

  • For Special Complex Crimes like:
    • Robbery with Homicide,
    • Robbery with Rape,
    • Robbery with Intentional Mutilation,
    • Robbery with Arson,
    • Rape with Homicide,
    • Kidnapping with Murder,
    • Carnapping with Homicide,
    • Carnapping with Rape,
    • HIghway Robbery with Homicide,
    • QUalified Piracy,
    • Arson with Homicide,
    • Hazing with Death, Rape, Sodomy or Murder, and
    • other crimes with death, injuries, and sexual abuse as the composite crimes, where the penalt consists of indivisible penalties:

where the penalty imposed is Death but reduced to reclusion perpetua because of RA 9346:

  1. Civil indemnity – P100,000
  2. Moral damages – P100,000
  3. Exemplary damages – P100,000

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SNOW NOTE:

Please inform me where there are type-o’s 😁 So far I haven’t seen any non-pdf files for the cases so I’ve been typing them so far 🤣

Thank you 🤗

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