1. Pro Reo Principle

B. Construction or Interpretation of Penal Laws

• Effects of Repeal/Amendments of Penal Laws; Repeal by Reenactment
• Retroactive Effect of Penal Laws
• Pro Reo Principle
• Suppletory Application of the Revised Penal Code to Special Laws – RPC, art. 10

PRO REO PRINCIPLE

The principle dictates that in cases of doubt or ambiguity regarding the interpretation of the law, the decision must be made in favor of the accused (in dubio pro reo).

This principle ensures fairness in criminal proceedings and is applied in instances such as:

• Ambiguity in Statutory Provisions: When there is uncertainty in the interpretation of a law, the construction most favorable to the accused must be adopted.
• Evaluation of Evidence: If the evidence presented is conflicting or insufficient to prove guilt beyond a reasonable doubt, the accused must be acquitted.
• Sentencing: If there are multiple possible punishments, the least severe one should be imposed if the law does not clearly favor a harsher sentence.

Applicability of Principle

Penal statutes should be strictly construed against the State only when the law is ambiguous and there is doubt regarding its interpretation. Where the law is clear and unambiguous, there is no room for the rule to apply. [People v. Gatchalian, G.R. No. L12011-14 (1958)] In dubio pro reo.

Cf. Rule of Lenity

Between two potential interpretations of a penal law, one prejudicial and another favorable, the more lenient one must be adopted. [Ient v. Tullett, G.R. No. 189158 (2017)] Case-name verification required: G.R. No. 189158 is identified as Ient v. Prebon (Jan. 11, 2017). Verify the case name before changing the citation.

Basis: All doubts shall be construed in favor of the accused and on the presumption of his innocence [Art. III, Sec. 14(2), 1987 Constitution]

When court believes in only 1 witness

The two-witness rule is not satisfied if the court believes in only one witness (People v Adriano, GR No. L-477)