Self-Defense & Justifying Circumstances (RPC)

Answer Summary

Under Article 11 of the Revised Penal Code, six justifying circumstances negate criminal liability. These are: (1) self-defense; (2) defense of relatives; (3) defense of a stranger; (4) state of necessity (avoidance of greater evil); (5) fulfillment of a duty or lawful exercise of a right or office; and (6) obedience to a lawful order of a superior. When self-defense, defense of relatives, or defense of a stranger is successfully established, the accused incurs no criminal liability and is likewise absolved of civil liability, because the act is considered lawful. An exception applies to the state of necessity under Article 11(4): the person who benefited from the avoided evil may remain civilly liable under Article 101 of the Revised Penal Code.

The governing statute is Republic Act No. 3815 (Revised Penal Code), Article 11, read in conjunction with Article 101 on civil liability. The Supreme Court has repeatedly defined the requisites of self-defense: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel it; and (3) lack of sufficient provocation on the part of the person defending himself. These same first and second requisites apply to defense of relatives and defense of a stranger, with an additional requirement specific to each. The leading decisions include Ernesto Andres v. Court of Appeals, G.R. No. L-48957 (23 June 1987), which held that unlawful aggression is the conditio sine qua non of self-defense; Daniel Aquino y Espiritu v. People, G.R. No. 274077 (24 February 2025), which confirmed that complete self-defense absolves the accused of both criminal and civil liability; Norman Lacson v. Court of Appeals, G.R. No. L-46485 (21 November 1979), on reasonable necessity; and People v. Dio scoro Alconga, G.R. No. L-162 (30 April 1947), which established that the right of self-defense ceases when the aggressor flees. Recent jurisprudence in 2025 continues to apply these settled principles without alteration.

The essential elements are: Unlawful aggression — an actual or imminent, unlawful physical attack that places the defender’s life or personal safety in real peril; it must be continuing at the moment of the defensive act. Reasonable necessity of the means employed — the defensive act must be rationally equivalent to the attack, judged from the subjective standpoint of the person under attack at the time of the emergency, not by material commensurability. Lack of sufficient provocation — the defender must not have given cause for the aggression through unjust or improper conduct. For defense of relatives, the defender must have had no part in any provocation given by the person attacked. For defense of a stranger, the defender must not be actuated by revenge, resentment, or other evil motive.

The most common failure points are: (a) absence of unlawful aggression — vague, inconsistent, or inherently incredible testimony will not suffice, as in Eduardo Ilayat v. People, G.R. No. 259916 (25 July 2025); (b) cessation of unlawful aggression before the defensive act — once the aggressor is disarmed, subdued, or fleeing, the right to self-defense evaporates (Senoja v. People, G.R. No. 160341 (2004); People v. Alconga, G.R. No. L-162); (c) failure to discharge the burden of proof — the accused must prove self-defense with clear and convincing evidence, relying on the strength of his own case and not on the weakness of the prosecution’s (Andres v. Court of Appeals, G.R. No. L-48957).

No legislative amendment to Article 11 has occurred in the last decade. The controlling doctrine remains stable. The most recent Supreme Court rulings from 2025 reiterate the classic tripartite test. Based on comprehensive research, no rulings from 2026 were found; the most recent authority is Eduardo Ilayat v. People, G.R. No. 259916 (25 July 2025).

Section I — Issue Overview

1. What are the justifying circumstances under Article 11 of the Revised Penal Code, and what is their effect on criminal and civil liability? — This issue identifies the six statutory grounds that render an otherwise criminal act lawful, and delineates the general rule that they extinguish criminal liability, as well as the limited exception concerning civil liability for the state of necessity.

2. What are the elements of self-defense, defense of relatives, and defense of a stranger under Article 11? — This issue isolates the precise legal requisites for each of the three defense‑based justifying circumstances, highlighting the common core and the additional conditions unique to defense of relatives and defense of strangers.

3. How do Philippine courts interpret and apply the requisites of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation? — This issue examines the jurisprudential gloss on each of the three constitutive elements of self-defense, which are the foundation for the analogous defenses.

Section II — Legal Analysis

Issue 1: Justifying circumstances under Article 11 and their effect on criminal and civil liability

Applicable Laws & Issuances

Revised Penal Code (Act No. 3815), Article 11 enumerates six justifying circumstances: (1) self-defense; (2) defense of relatives; (3) defense of a stranger; (4) state of necessity (avoidance of an evil or injury); (5) fulfillment of a duty or lawful exercise of a right or office; and (6) obedience to a lawful order of a superior. The opening clause states: “The following do not incur any criminal liability.”

With respect to civil liability, the rule is nuanced. Article 11 itself does not address civil liability directly. The governing provision is Article 101 of the Revised Penal Code, which provides that persons exempt from criminal liability (a category that includes those acting under justifying circumstances) may still be civilly liable under certain conditions. However, because a justifying circumstance renders the act lawful ab initio (from the beginning), the general rule is that no civil liability attaches to self-defense, defense of relatives, defense of a stranger, fulfillment of duty, or obedience to a lawful order. The exception is the state of necessity under Article 11(4): the Code expressly notes that “subdivision 4 of Article 11 of this Code does not include exemption from civil liability,” meaning the person who benefited from the prevention of a greater evil may be held civilly answerable. This principle is confirmed by multiple authorities, including the official text of the Revised Penal Code as published by the United Nations repository. (See [PDF] Philippines Revised penal code — www.un.org)

Case Law Analysis

Daniel Aquino y Espiritu v. People, G.R. No. 274077 — 24 February 2025

Focus of Dispute: Whether the accused’s killing of the victim constituted homicide or was justified by complete self-defense, and the corresponding effect on criminal and civil liability.

Facts: During a brawl at a construction site, the victim pursued the accused, initiated a physical fight, pinned him to the ground, and began strangling him. The accused stabbed the victim, causing death. The lower courts convicted him of homicide with incomplete self-defense. The Supreme Court reversed.

Disposition: The Court acquitted the accused on the ground of complete self-defense, holding that all three requisites were satisfied.

Ratio Decidendi: The Court applied the subjective test for reasonable necessity and found that the instinct of self-preservation justified the means employed. Crucially, it ruled that a finding of complete self-defense “absolves him of both criminal and civil liability.” This is consistent with the principle that a lawful act generates no civil ex delicto obligation.

Evidence Evaluated: The Court credited the accused’s consistent testimony and the surrounding circumstances that showed continuous unlawful aggression and a real threat to life.

Precedential Status: The ruling is a recent Division decision that reaffirms settled doctrine; it is the most current pronouncement on the civil liability effect of self-defense.

United States v. Eng-Jua, G.R. No. 4685 — 17 September 1908 (En Banc, J. Carson)

Focus of Dispute: Whether defendants could be exempt from criminal liability under the defense‑of‑stranger provision (then Section 6, Article 8, Penal Code) when they wounded the complainant after a prior altercation had ended.

Facts: The defendants attacked the complaining witness after a dispute between their friend and the witness had already terminated. The trial court convicted them.

Disposition: The Supreme Court affirmed the conviction.

Ratio Decidendi: The Court held that at the time of the defendants’ intervention, the unlawful aggression against their friend had ceased, and their attack was “actuated rather by revenge and resentment… than by a desire to prevent or repel assault upon him.” This case illustrates the principle that the right to defend a stranger is conditioned on the presence of continuing unlawful aggression and the absence of an evil motive.

Evidence Evaluated: The record disclosed that the prior altercation was over before the defendants appeared, and their subsequent attack was not protective.

Precedential Status: A foundational, pre‑Code decision construing the predecessor of Article 11(3); its core holding — that the defense must be contemporaneous with the aggression and not driven by illicit motive — remains good law.

G.R. No. 260353 (8 February 2023) — Camillo v. People

Focus of Dispute: Self-defense plea in a homicide prosecution; whether all three requisites were present and the effect on civil liability.

Disposition: The Supreme Court ruled that self-defense was established, resulting in acquittal.

Ratio Decidendi: The Court explicitly stated: “A finding of self‑defense relieves the accused of both criminal and civil liability (Article 101, RPC; People v. Malicdem, 698 Phil. 408).” It also reiterated the definitions of unlawful aggression and the reasonable necessity standard. The case reinforces the rule that self-defense, once proven, eradicates civil as well as criminal liability.

Precedential Status: A 2023 Division decision that aligns with long-standing precedent; valuable for its succinct restatement of the civil liability principle.

Recent Developments

No legislative amendments to Article 11 or Article 101 of the Revised Penal Code have been adopted in recent years. The most recent jurisprudence — Daniel Aquino (2025) and G.R. No. 260353 (2023) — consistently holds that a successful plea of self-defense, defense of relatives, or defense of a stranger extinguishes both criminal and civil liability. The narrow exception for the state of necessity (Article 11, par. 4) continues to be reflected in authoritative statutory compilations and commentaries.

Analysis

All six justifying circumstances listed in Article 11 share the effect of negating criminal liability. This is because the law deems the act lawful; there is no crime. The civil liability consequence flows from the nature of the act: if the act is entirely lawful, no civil liability ex delicto (from the offense) arises. The Supreme Court has expressly stated this principle in Daniel Aquino and G.R. No. 260353. The sole qualification concerns the state of necessity, where Article 11(4) permits the person who benefited from the avoided evil to be held civilly liable. Practitioners should therefore advise that a full acquittal on the ground of self-defense, defense of relatives, or defense of a stranger — once final — precludes any subsequent civil action for damages based on the same act, because the act was juridically lawful.

Issue 2: Elements of self-defense, defense of relatives, and defense of a stranger under Article 11

Applicable Laws & Issuances

Revised Penal Code (Act No. 3815), Article 11, paragraphs 1, 2, and 3 sets out the specific requisites.

• Self-defense (par. 1): “Anyone who acts in defense of his person or rights, provided that the following circumstances concur: First. Unlawful aggression; Second. Reasonable necessity of the means employed to prevent or repel it; Third. Lack of sufficient provocation on the part of the person defending himself.”

• Defense of relatives (par. 2): “Anyone who acts in defense of the person or rights of his spouse, ascendants, descendants, or legitimate, natural or adopted brothers or sisters, or of his relatives by affinity in the same degrees, and those by consanguinity within the fourth civil degree, provided that the first and second requisites prescribed in the next preceding circumstance are present, and the further requisite, in case the provocation was given by the person attacked, that the one making defense had no part therein.”

• Defense of a stranger (par. 3): “Anyone who acts in defense of the person or rights of a stranger, provided that the first and second requisites mentioned in the first circumstance of this article are present and that the person defending be not induced by revenge, resentment, or other evil motive.”

Thus, all three defenses share the first two requisites (unlawful aggression and reasonable necessity of the means). Self-defense adds the third element of lack of provocation on the defender. Defense of relatives modifies the third element: if the person attacked gave provocation, the defender must have had no part in it. Defense of a stranger replaces the third element with the requirement that the defender must act without revenge, resentment, or evil motive.

Case Law Analysis

Ernesto Andres v. Court of Appeals, G.R. No. L-48957 — 23 June 1987 (J. ——)

Focus of Dispute: Whether petitioner could invoke self-defense under Article 11 in a prosecution for homicide and frustrated homicide.

Facts: The petitioner, after an earlier altercation that was peacefully settled, later caught up with the victims and stabbed them without warning, killing one and wounding another. He claimed the victims attacked him first with fists and a club.

Disposition: The Supreme Court denied the petition and affirmed the conviction.

Ratio Decidendi: The Court declared: “The first requisite of self-defense is indispensable. There can be no self-defense until it is proved that there has been unlawful aggression on the part of the person injured or killed by the accused.” It further held that “[i]f there is no unlawful aggression, there is nothing to prevent or to repel. The second requisite of self-defense will have no basis.” The Court refused to discuss the other requisites because the initial element was absent.

Evidence Evaluated: The defense evidence was found “full of contradictions and improbabilities”; the accused’s claim of injuries was uncorroborated, and the scene was a crowded road, contradicting the alleged gang attack.

Precedential Status: Continues to be cited for the proposition that unlawful aggression is the conditio sine qua non and that the burden of proof rests on the accused.

Carlos Del Prado v. People, G.R. No. 230351 — 6 September 2017

Focus of Dispute: Claims of self-defense or defense of a relative in a double homicide.

Disposition: The petition was denied; the appellate decision affirmed with modified damages.

Ratio Decidendi: The Court emphasized that “the justifying circumstance of self-defense or defense of relative, and consequently, the lack of intent to kill, must be proven by the accused through clear and convincing evidence.” The lower courts’ factual findings that unlawful aggression was not established were accorded great weight and not disturbed.

Precedential Status: Reinforces the evidentiary burden and the principle that appellate courts will defer to the trial court’s assessment absent exceptional circumstances.

Ronnie Zingapan v. People, G.R. No. 238144 — 4 July 2018

Focus of Dispute: Petitioners’ simultaneous invocation of self-defense and defense of a stranger.

Disposition: Petition denied; convictions affirmed.

Ratio Decidendi: The Court found that petitioners failed to prove unlawful aggression by the private complainants. With regard to defense of stranger, the Court of Appeals correctly held that “the unlawful aggression against Regino Calimag had ceased at the time petitioners began attacking private complainants.” This illustrates the critical temporal requirement for both self-defense and defense of stranger.

Precedential Status: A recent Division minute resolution that confirms the cessation rule.

Jerson Juyad v. People, G.R. No. 215648 — 11 March 2015

Focus of Dispute: Self-defense claim in frustrated murder.

Disposition: Petition denied; conviction affirmed.

Ratio Decidendi: “As correctly held by the CA, the element of unlawful aggression must first be proven in order for a plea of self-defense to prosper. However, records are bereft of evidence showing that Norberto Aguanta Oscares assaulted or at least threatened to inflict real injury upon petitioner, as in fact, the former was unarmed and the attack of petitioner was sudden and unexpected.”

Precedential Status: Reinforces the requirement that the victim must have been the initial aggressor.

Recent Developments

No new doctrinal developments alter the statutory elements. The decisions discussed above remain the governing law. Web‑sourced analyses (e.g., Legal Resource PH — legalresource.ph; NDV Law — ndvlaw.com) restate the same elements without deviation.

Analysis

To invoke any of the three defense‑based justifying circumstances, the accused must prove the presence of unlawful aggression and reasonable necessity of the means by clear and convincing evidence. The distinctive conditions operate as follows:

• For self-defense, the defender must also lack sufficient provocation. If the defender provoked the aggression, the defense fails entirely or may be downgraded to incomplete self-defense.
• For defense of relatives, the personal provocation element is replaced by the condition that if the person attacked gave the provocation, the defender must not have participated in it. This recognizes that a relative may have incited the fight, but the defender may nonetheless act lawfully if he or she was not an accessory to the provocation.
• For defense of a stranger, the law requires a purified motive: the defender must not be “induced by revenge, resentment, or other evil motive.” This ensures that the defense is genuinely protective and not a pretext for settling private scores.

Thus, a practitioner raising these defenses must carefully plead and prove the specific additional requirement. Evidence of prior relationship, history of conflict, and the immediate circumstances of the intervention will be critical.

Issue 3: Jurisprudential construction of unlawful aggression, reasonable necessity, and lack of sufficient provocation

Applicable Laws & Issuances

Article 11, paragraph 1, of the Revised Penal Code sets out the three requisites in terse language. The Supreme Court has supplied extensive interpretive gloss that is controlling.

Case Law Analysis

Unlawful Aggression

Eduardo Ilayat v. People, G.R. No. 259916 — 25 July 2025

Focus of Dispute: Self-defense claim where the accused alleged the victim choked him.

Disposition: Petition denied; conviction for homicide affirmed.

Ratio Decidendi: The Court held that “Unlawful aggression is a conditio sine qua non for upholding the justifying circumstance of self-defense; if there is nothing to prevent or repel, the other two requisites of self-defense will have no basis.” It found that the accused’s and his witness’s versions of how the aggression supposedly started were contradictory, and the minor abrasions the accused sustained did not indicate a life‑threatening attack. “Eduardo said… suddenly, [the victim] choked him. On the other hand, [his witness] clearly stated that it was the men of [the victim] who ran after them and Eduardo was caught by four men… these contradictions… short to establish clear and convincing proof.”

Evidence Evaluated: The defense evidence was contradictory; medical certificates showed only superficial scratches.

Precedential Status: The most recent pronouncement (July 2025) on the necessity of coherent, clear evidence of unlawful aggression.

G.R. No. 260353 (2023) explained the two recognized species of unlawful aggression:

“(a) actual or material — an attack with physical force or a weapon; (b) imminent — an attack that is impending, as when a person is aiming a revolver at another with intent to shoot. A mere threatening attitude is insufficient; there must be a positive, offensive act.”

People v. Annibong, G.R. No. 139879 — 8 May 2003 (En Banc): the Court rejected self-defense because the initial aggression had ceased — the victim was walking away, thus there was no imminent danger.

People v. Alconga, G.R. No. L-162 — 30 April 1947 (En Banc): “a fleeing man is not dangerous to the one from whom he flees.” The right of self-defense terminated when the wounded victim fled.

Exequiel Senoja v. People, G.R. No. 160341 — 19 October 2004: the cessation of unlawful aggression negates self-defense.

Reasonable Necessity of the Means Employed

Daniel Aquino v. People, G.R. No. 274077 — 24 February 2025

Ratio Decidendi: The Court emphasized that the test is “reasonable necessity, not absolute necessity.” It stated:

“The requirement of reasonable necessity does not demand material commensurability but rational equivalence. The defense must be judged from the accused’s subjective standpoint at the time, taking into account the emergency and the instinct of self‑preservation; the law does not require unerring judgment when there is apparent danger of death or great bodily injury.”

The Court found that the accused’s use of a knife while being strangled and pinned to the ground was rationally necessary.

Norman Lacson v. Court of Appeals, G.R. No. L-46485 — 21 November 1979

Ratio Decidendi: The Supreme Court reversed the lower courts’ finding of incomplete self-defense, holding that all three elements were present. The victim’s statement “ito ang batas” (this is the law) while threatening indicated he was armed, and given his violent character and intoxication, the use of a gun was reasonable. The Court articulated:

“Reasonable necessity of the means employed to prevent or repel the attack does not mean material commensurability between the means of attack and defense. What the law requires is rational equivalence, in the consideration of which will enter the emergency, the imminent danger to which the person attacked is exposed, and the instinct, more than reason, that moves a person to defend himself.”

G.R. No. 248130 (2020), citing People v. Olarbe, restated the test: “the law does not require unerring judgment when there is apparent danger of death or great bodily injury. The right of a person to take life in self-defense arises from his belief in the necessity for doing so; and his belief and the reasonableness thereof are to be judged in the light of the circumstances as they then appeared to him.”

Lack of Sufficient Provocation

Eduardo Ilayat v. People, G.R. No. 259916 illustrates that the defender must not have given sufficient provocation. The Court rejected the mitigating circumstance of “sufficient provocation” because the evidence showed the victim’s group was merely attempting to pacify the accused. The accused’s own unruly conduct and brandishing of a knife initiated the chain of events; therefore, he could not claim self-defense.

The web commentary from NDV Law defines provocation as “unjust or improper conduct on the part of the defender that incites the aggression.” If the defender was the initial provocateur, the element fails.

Recent Developments

The 2025 cases of Aquino and Ilayat confirm that the standards for unlawful aggression and reasonable necessity remain as articulated in earlier precedents. No doctrinal shift is observed. The web‑sourced 2023 and 2020 rulings further solidify the two‑species test for unlawful aggression and the subjective‑rational‑equivalence standard for reasonable necessity.

Analysis

In practice, a lawyer must build a defense around the following:

• Unlawful aggression: present clear, consistent, and credible evidence — ideally corroborated by physical injuries, medical reports, and unbiased witnesses — that the victim launched an actual or imminent physical attack. Any inconsistency in the defense narrative will be fatal, as seen in Ilayat. The aggression must be ongoing at the instant of the defensive act; a gap or cessation in time bars the defense.
• Reasonable necessity: do not engage in a mechanical comparison of weapons. Instead, frame the defense from the subjective standpoint of the accused at the critical moment, emphasizing the emergency, the perceived threat to life, and the instinct for self‑preservation. A knife against fists may be reasonable if the victim was strangling or otherwise overpowering the accused.
• Lack of provocation: the accused must demonstrate that he or she did nothing to incite the aggression. If the accused was the initial aggressor, the claim of self-defense collapses. For defense of relatives and strangers, the focus shifts to the defender’s non‑participation in any provocation and the purity of motive, respectively.

The burden of proof — “clear and convincing evidence” — is consistently imposed. The failure to meet it on any single requisite is fatal to the entire defense.

Section III — Action Plan & Evidence Guide

Recommended Strategy: Defending a client charged with a crime by raising a justifying circumstance under Article 11 requires a proactive, evidence‑intensive approach. Because the burden shifts to the defense, the preparation of a coherent, well‑documented narrative that satisfies all three (or the applicable) requisites is paramount. Begin immediately with witness interviews, physical evidence preservation, and scene documentation.

Action Steps

1. Secure immediate medical examination of the accused — Document any injuries (bruises, abrasions, lacerations) within 24–48 hours. Medical certificates and photographs are crucial to corroborate unlawful aggression and the necessity of the response. These records must align with the defense timeline.

2. Obtain sworn statements from all eyewitnesses — Interview and secure affidavits from individuals who observed the incident, concentrating on who started the physical encounter, the nature of the victim’s acts (whether an actual strike or threatening gesture with a weapon), and the accused’s reaction. For defense of relatives or strangers, identify the person being defended and the exact moment of aggression against that person.

3. Preserve and photograph the scene — Note distances, obstacles, and lighting. If weapons were involved, document their type and condition. For a defense of stranger, gather evidence of the relationship (or lack thereof) between the accused and the stranger to negate improper motive.

4. Prepare a detailed chronological narrative of the accused’s subjective perception — The accused’s testimony must articulate the perceived danger: “I thought he would kill me because…” or “I saw him reach for his waist as if drawing a gun.” The belief must be judged from his standpoint at the time, not with hindsight.

5. File appropriate pleadings to raise the defense early — In the pre‑trial brief or at arraignment, explicitly invoke the applicable paragraph of Article 11. This puts the court and prosecution on notice and frames the trial.

6. Engage expert witnesses if needed — A ballistics or forensic expert may be necessary to demonstrate that the means employed were not grossly disproportionate or that the victim’s weapon was real. A psychologist can testify to the accused’s state of mind during the emergency.

Evidence Checklist

• Medical/medico‑legal certificate of the accused — proves unlawful aggression and the accused’s injuries; obtain from attending hospital or medico‑legal officer of the PNP/NBI.
• Photographs of the accused’s injuries — supplement medical findings; secure immediately after the incident.
• Sworn affidavits of disinterested eyewitnesses — attest to the victim being the initial aggressor; capture through immediate investigation.
• Weapon or object used by the victim (if any) — demonstrates actual or imminent threat; retrieve from crime scene or police custody.
• The accused’s sworn statement or judicial affidavit — outlines the subjective perception of danger, lack of provocation, and absence of improper motive.
• Records of prior incidents involving the victim — if the accused knew of the victim’s violent character, this can support reasonable necessity; obtain from police blotters or community records.
• Proof of relationship (for defense of relatives) — birth certificates, marriage certificate, or affidavit of filiation to establish the familial link within the degrees specified by law.
• Evidence of non‑participation in provocation (for defense of relatives) — testimony that the defender did not instigate or join in the provocation given by the person attacked.
• Character evidence concerning the accused and the victim — relevant to reasonable necessity and motive; gather from community members.

⚠️ This is AI-generated legal research for reference only. It does not constitute legal advice. Consult a licensed Philippine attorney before making important legal decisions.

References

Legislation & Regulatory Issuances

• Revised Penal Code (Act No. 3815)
• [PDF] Philippines Revised penal code — www.un.org

Case Law

• Daniel Aquino y Espiritu v. People, G.R. No. 274077 (24 February 2025)
• Ernesto Andres v. Court of Appeals, G.R. No. L-48957 (23 June 1987)
• Norman Lacson v. Court of Appeals, G.R. No. L-46485 (21 November 1979)
• Eduardo Ilayat v. People, G.R. No. 259916 (25 July 2025)
• United States v. Eng-Jua, G.R. No. 4685 (17 September 1908)
• Ronnie Zingapan v. People, G.R. No. 238144 (4 July 2018)
• Jerson Juyad v. People, G.R. No. 215648 (11 March 2015)
• Carlos Del Prado v. People, G.R. No. 230351 (6 September 2017)
• The People of the Philippines v. Dio scoro Alconga, G.R. No. L-162 (30 April 1947)
• Exequiel Senoja v. People, G.R. No. 160341 (19 October 2004)
• People v. Gabriel Annibong, G.R. No. 139879 (8 May 2003)
• Jose Marcon Encio Desalisa v. People, G.R. No. 234881 (22 January 2018)
• G.R. No. 260353 (8 February 2023) — Camillo v. People
• G.R. No. 248130 (2 December 2020) — Ganal v. People