Rosal Hubilla was only 17 years old when he stabbed Jason Espinola during a graduation ceremony in Camarines Sur.

Jason initially survived the attack and underwent surgery. More than a month later, however, complications from the stab wound led to overwhelming infection and organ failure. He eventually died. Rosal was charged and later convicted of homicide.

Rosal no longer disputed his conviction before the Supreme Court. By the time his case reached the Court, the Juvenile Justice and Welfare Act (Republic Act No. 9344) had already taken effect. Rosal argued that because he was a child in conflict with the law when the crime was committed, he should benefit from the law’s protective provisions. He insisted that he should not be sent to prison and should instead be allowed probation or the suspension of his sentence. Was he correct?

The Supreme Court disagreed. The Court first acknowledged that Rosal’s minority worked in his favor. Since he was only 17 years old when he committed the crime, his age constituted a privileged mitigating circumstance that reduced the penalty for homicide. Applying the Revised Penal Code and the Indeterminate Sentence Law, the Court upheld the reduced sentence imposed by the Court of Appeals. Rosal nevertheless argued that his sentence should be reduced even further so that he could qualify for probation.

The Court rejected the argument. According to the Court, neither the Juvenile Justice and Welfare Act nor any other law authorized judges to further reduce an otherwise lawful sentence simply to make an accused eligible for probation. Doing so would amount to imposing an illegal penalty.

Rosal also claimed that his sentence should have been suspended under Republic Act No. 9344.

Again, the Court disagreed. The law allows the suspension of sentence for children in conflict with the law only until they reach 21 years of age. By the time the trial court convicted Rosal, he was already over 23 years old. The benefit was therefore no longer legally available to him.

Finally, Rosal argued that sending him to prison violated the spirit of the Juvenile Justice and Welfare Act and international agreements protecting children.

The Supreme Court explained that this was a misunderstanding of the law. The Juvenile Justice and Welfare Act does not absolutely prohibit imprisonment. Rather, it treats imprisonment as a last resort and requires that it be imposed only for the shortest appropriate period. International standards adopted by the Philippines recognize the same principle.

Because Rosal was no longer qualified for probation or suspension of sentence, imprisonment became legally proper. The Court, however, directed that he serve his sentence in an agricultural camp or other training facility maintained by the Bureau of Corrections in coordination with the Department of Social Welfare and Development, instead of an ordinary penal institution. This arrangement reflected the law’s continuing concern for the rehabilitation of youthful offenders while still holding them accountable for serious crimes.

Accordingly, the Supreme Court affirmed Rosal’s conviction and sentence, subject to the directive that he serve his imprisonment in a facility appropriate for offenders who committed crimes while still minors.

Hubilla v. People. G.R. No. 176102, November 26, 2014