G.R. No. L-62114 July 5, 1983
ISIDRO BERNARDO and CAYETANO BERNARDO, petitioners, vs. THE PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Isidro Bernardo was a tenant on a riceland owned by Ledda Sta. Rosa in Plaridel, Bulacan, from 1972 to 1974. During his tenancy, he constructed a house on the land for his family, with his son and co-petitioner Cayetano Bernardo residing with him as a helper. Isidro later left the landholding without the landowner’s knowledge, transferring his tenancy rights to Cayetano, who continued to occupy the house. After Sta. Rosa regained possession of the land, she filed a civil action for forcible entry against the petitioners, prevailing in the Municipal Court, the Court of First Instance, and the Court of Appeals. Following a demand to vacate, a criminal complaint was filed against the petitioners for violating Presidential Decree No. 772 (Anti-Squatting Law).
The information alleged that the petitioners willfully and unlawfully possessed and squatted on the land by erecting and failing to remove their residential house despite demand. Upon arraignment, they pleaded not guilty. After trial, they filed a motion to dismiss, arguing that PD 772 applied only to urban communities and not to agricultural lands, citing the case of People vs. Echaves. The trial court denied the motion, convicted the petitioners, and sentenced each to pay a fine.

ISSUE

Whether the petitioners can be validly convicted for violating Presidential Decree No. 772 for squatting on agricultural land.

RULING

No. The Supreme Court granted the petition and set aside the conviction. The legal logic hinges on the proper interpretation of the scope and intent of Presidential Decree No. 772. The Court, reiterating its ruling in People vs. Echaves, examined the decree’s preamble, which explicitly references the problem of squatting “in urban communities” and the directive to remove illegal constructions on public and private property within that context. The preamble’s language confines the decree’s application to squatting in urban settings.
The Court emphasized the principle of strict construction of penal laws, as articulated in US vs. Abad Santos, which holds that no person should be brought within the terms of a penal statute who is not clearly within them, and no act should be pronounced criminal which is not clearly made so by the statute. Since the subject land was agricultural riceland and not within an urban community, the acts of the petitioners did not fall within the ambit of PD 772. Therefore, the facts alleged and proven did not constitute a violation of that law. Consequently, the trial court had no jurisdiction to convict them for such an offense, rendering its judgment null and void. The criminal case was ordered dismissed.