Crim Reviewer
August 13, 2022 | Author: Anonymous | Category: N/A
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Criminal Law – A branch or division of law which denes crimes, treats of their nature and provides for their punishment. – Body of law that relates to crime Body of rules that denes conduct that is prohibited by the State because it is held – to threaten, harm, or endanger the safety and the welfare of the public, and that sets out punishment to be imposed on those who breach these laws. 6.
CRIME -
is an act commi commied ed or omied in violaon of a public law forbid forbidding ding or
commanding it; o
Alters rules of evidence and auhori0es conic&on upon less or di4erent tesmony than the law re5uired at the me of the commission of the crime o Imposes penal1 penal1 or #epria&on of a ri'h ri'h for something which when done was lawful o (prolamaon n o! amnesty) !epries an accuse# some lawful proec&on (prolamao &ust n no ot p pa arta*e o off tth he n na ature o off a 2ill of a3ain#er. 4ill of A3ain#er o
o
An act or instance of negligence that is deemed inurious to the public welfare or morals or to the interests of the State that is l egally prohibited
#egislave act which would in7ict punishment without udicial trial ssence8 ssen ce8 substuon of a legis legislave lave act for the udicial udicial term terminaon inaon of guilt 'o person shall be held to answer for a crime wihou #ue process of law o
9.
Sources of Philippines Criminal Law Revised !enal "ode and its amendments Philippine ne Commission, Assembly, Assembly, L egislature; Naonal Special !enal #aws (passed by the Philippi Assembly,, Congress, Batasang P Assembly Pambansa) ambansa) Penal !residenal $ecrees issued during Maral Law
CONS5I5$5IONAL RI6%5S of he ACC$SE! :ight to a speedy disposion 'o person shall be held to answer for a cri me without due process of law :ight to bail before convicon e-cept reclusion perpetua< even the privilege of the writ of habeas orpus is suspended Accused shall be presumed innocent unl the contrary is proved, enoy right to be heard by himself and counsel, meet witnesses face to face, secure the aendance of witnesses and producon of evidence 'o person shall be compelled to be a witness against himself :ight to remain silence -cessive =ines shall not be imposed "ruel punishment shall not be in7icted 'o double eopardy =ree access to courts and 5uasiudicial bodies and ade5uate legal assistance
*No COMMON LAW Crimes in he Philippines "%&&%' #A( ) *nown in +S and ngla ngland nd as the body of principles, principles, usage usagess and rules of acon which do not rest for their authority upon any e-pres e-presss and posiv posive e declarao declaraon n of the will of the legislature. principles and rules of acon, embodied in case law rather rather than legislave enactments, applicable to the government and protecon of persons and property that derive their authority from the community customs customs and tradions tradions that evol evolved ved over the centuries centuries as inter interpret preted ed by udicial tribunals. /"ourt decisions ) not sources of criminal law because they merely e-plain the meaning of, and apply, the law as enacted by the legislave branch of the gov0t.
S5A5$5OR7 RI6%5S of he ACC$SE! 1o be presumed innocent unl the contrary is provided 1o be informed of the nature and cause of accusaon 1o be present and defend in person and by counsel at every stage of the proceedings 1o tesfy as a witness in his own behalf but sub"et to ross#e$aminaon 1o be e-empt from being compelled to be a witness against himself 1o confront and crosse-amine the witnesses against himself 1o secure the aendance of witnesses and producon of evidence 1o have a speedy, imparal and public t rial 1o appeal in all cases allowed and in the manner prescribed by law
*Power o !E"INE an# P$NIS% CRIMES 1he 1he Sae has the authority, under its police power, to dene, prosecute, and punish crimes and to lay down the rules of criminal procedure. POLICE POLIC E POWER – describes the basic rights of the State to ma*e laws governing safety, health, welfare and morals
Limia&ons on he power of Con'ress o enac penal laws (ON) 2. &ust &ust be g gen ener eral al in ap appli plica cao on n and must must clea clearl rly y de dene ne the the acts acts and om omis issi sion onss pun punis ishe hed d as crimes. 3. & us ust no no t p ar ar tta a*e o off t h he e na att ur ure o off an ex post facto law. !rohibits the passage of reroac&e laws which are pre+u#icial o he accuse# (,) E Pos "aco Law o &a* &a*es es an act done before the passag passage e of the law criminal. and which was innocent when done, and punishes the act o A''raaes a crime o In/ics a 'reaer punishmen than the law anne-ed to the crime when commied
/Ri'hs of he accuse# which ma1 an# ma1 no 2e waie# MA7 2e WAI8E! personal< right of the accused to confrontaon and crosse-aminaon MA7 NO5 2e WAI8E! public interest< right of the accused to be informed of the nature and cause of accusaon against him
C%ARAC5ERIS5ICS O" CRIMINAL LAW9 I: 6ENERAL ) the law is binding to all persons who reside in the !hilippines 1 |
/ 1he jurisdicon of civil courts is not aected by character of the accused by the military character / Civil courts have concurrent jurisdicon with general courts-maral over over soldiers of the A=! (e%en in mes o! war) / (hen military courts ta*e cogni>ance of the case involving a person subect to military law, Arcles of War War apply, not the :evised !enal "ode or other penal law /;uris#ic&on of miliar1 cours – &ilitary courts have urisdicon over ? service-oriented crimes or oences@ as specied by the Ar cles of (ar / 1he prosecuon of an accused before a courtmaral is a 2ar to another prosecuon of the
/ A repeal is par&al or rela&e when the crime punished under the repealed law onnues to be a a4ecng the rime in spite of the repeal. 1his means that the repeal merely modied the condions a4ecng crime under the repealed law. 1he modicaon may be prejudicial or bene$cial to to the o4ender. 1ene, the !ollowin !ollowing g rule2
Conse>uences if repeal of penal law is 5O5 5O5AL AL OR A4SOL$5E
accused for the same o4ense / Ouences if repeal of penal law is PAR5IAL OR RELA5I8E
II: 5ERRI5ORIAL ) the law is binding to all crimes commied within the 'aonal 1erritory of the !hilippines. !enal laws of the !hilippines are enforceable only within its territory.
(3)
Cf a case is pen#in' in court involving the violaon of the repealed law, and the repealing law is more favorable to the accused it shall be the one applied to him& So whether he is a habitual delin4uent or not , if the case is sll pending in court, the repealing law will be the one to apply unless there is a saving clause in the repealing law that it shall not apply to pending causes of acon.
3<
Cf a case is alrea#1 #eci#e# an# he accuse# is alrea#1 serin' senence by nal udgment , , e%en i! the repealing law is paral or rela%e, the crime sll remains to be a crime& 1hose who are no ha2iual #elin>uens will 2ene? on he euences if repeal of penal law is E=PRESS OR IMPLIE! Cf a penal penal law is implie#l1 repeale#, the the subse%uent repeal of the repealing law will rime under the reie he ori'inal law . So the act or omission which was punished as a ccrime origi original nal law will be revived revived and the same shall a'ain 2e crimes although during the implied repeal they may not be punishable.
(3)
Eed is not i nherently wrong, it is wrong only because a law punishes the same.
5hir# class of crimes ) punished by special laws When he crime is punishe# 21 a special law, intent to commit the crime is not necessary. nough that the o4ender has the intent to perpetrate the act prohibited by special laws
!is&nc&on 2eween IN5EN5 an# MO5I8E IN5EN5 is demonstrated by the use of a par&cular means o 2rin' a2ou a #esire# resul ) it is not a state of mind or a reason for commiOng a crime.
8ntent to commit the crime ) there must be criminal intent 1mala in se0 8ntent to perpetrate the act ) ) the prohibited act is done freely and consciously 1mala prohibia0
MO5I8E implies mo&on. Ct is the moin' power which impels one o #o an ac: (hen there is move in the commission of a crime, it always comes before before the intent. But a crime may be commi/ed without move. 'ot an essenal element of crime
A person may not have consciously intended to commit a crime; but he did not intend to commit an act, and that act by the very nature of things, the crime i tself.
(I' MO5I8E IS RELE8AN5 (here the i#en&1 of a person accuse# of having commied a crime is in ar'umen (here there is doubt as to the identy of the assailant Cn ascertaining the truth between ana'onis&c heories or ersions of he Billin' (here (her e the i#en&?ca&on of he accuse# proceeds from from an unrelia2le source and the es&mon1 is inconclusie and no free from #ou2 Cf the evidence is merel1 circumsan&a circumsan&all
MALA IN SE AN! MALA PRO%I4I5A MALA IN SE o Act is inherenl1 eil or bad or per se wrongful.:!"< o Wron'ful from their naure o So serious in their e4ects on society as to call for almost unanimous condemnaon of its members o Inen 'oerns o "elonies #e?ne# an# penali0e# 21 he RPC
(I' MO5I8E IS IRRELE8AN5 (hen the commission of he crime has 2een proen and evidence of i#en&?ca&on is conincin' (hen the accused has been posively idened (hen guilt is established by suHcient evidence
MALA PRO%I4I5A o Fiolaons of special laws, mere rules of convenience designed to secure a more orderly regulaon of the society special laws< o (rong merely because prohi2ie# 21 saues o Onl1 in>uir1 is@ :as the law been violated; o Acs ma#e criminal 21 special laws o Reise# Elec&on Co#e ) special law since it is not a part of the :!"
Cn those crimes punished by special laws, the ac, irrespe%e o! its mo%es, cons&ues he ouali?ca&on@ Perpeual or emporar1 special #is>uali?ca&on@ #is>uali?ca&on@ Suspension from pu2lic oce@ he ri'h o oe an# 2e oe# for for@@ he profession or callin': Ciil iner#ic&on@
=ines are imposed either as alternave Art 299 punishing disturbance of proceedings with arresto mayor or ne from 3 pesos to 2 pesos< or single ne of 3 to M pesos< !enalty !enalty cannot be imposed imposed in the alternave alternave since it0s the duty of the court to indicate indicate the penalty imposed denitely and posively. 1hus, the court cannot sentence the guilty person in a manner as such as ?to pay ne of 2 pesos, or to su4er an imprisonment of 3 years, and to pay the costs.@ Cf the ne imposed by the law for the felony is e-actly 3 pesos, it is a light felony. =ines8 a AUicve ) over M b "orreconal ) 32 to M c #ight ) 3 and less 'ote8 1he classicaon applies i f the ne is i mposed as a single or alternave penalty. Ience, it does not apply if the ne imposed together with another penalty. Bond to *eep the peace is by analogy8 a AUicve ) over M b "orreconal ) 32 to M c #ight ) 3 and less $isncon between classicaon of !enales in Art. P and Art. 3M Arcle P Arcle 3M
In#emni?ca&on@ "orfeiure or con?sca&on of insrumens an# procee#s of he ouali?ca&on: V 5he #ura&on of he penal&es penal&es of prision ma1or an# emporar1 #is>uali?ca&on shall 2e from si 1ears an# one #a1 o wele 1ears@ ecep when he penal1 of #is>uali?ca&on is impose# as an accessor1 penal1@ in which case is #ura&on shall 2e ha of he principal penal1:
d deprivaon of rights ) dis5ualicaon and suspension e pecuniary ) ne According to gravity a capital b aUicve c correccional d light !ublic censure is a penalty, and being such, is not proper in ac5uial. But a competent court, while ac5uiOng an accused may, with un5uesonable propriety e-press its disapproval or reprehension of those acts to avoid the impression that by ac5uiOng the accused it approves or admires his conduct. !ermanent and temporary absolute and permanent and temporary special dis5ualicaon and suspension may be principal or accessory penales because they are found in 3 general classes.
$eath
Ar: ,: ,: When aTic& aTic&e@ e@ correc&ona correc&onal@ l@ or li'h penal1 penal1:: V A ?ne@ wheh wheher er impos impose# e# as a sin'le of as an alerna&e penal1@ shall 2e consi#ere# an aTic&e penal1@ if i ecee#s @ pesosF a 34 |
1erm of Cmprison ment
'one
Accessory !enales
'o one ne,, unle unless s pardoned8 !erpetual absolute dis5ualicaon "ivil interdicon for 6 years
:eclusion !erpetua 3 days and 2 day to 9 years
:eclusion 1emporal 23 years years and 2 day to 3 years
"ivil Cnter Cnterdicon dicon or du urr in in g h is is sentence !erpetual absolute dis5ualicaon
"ivil Cnterdicon or du duri ring ng his his sentence !erpetual absolute dis5ualicaon
!rison &ayor M years and 2 day to 23 years 1emporary absolute dis5ualicaon !erpetual !erp etual special special dis5ualicaon from from the right right of su4rage su4ra ge which the
o4 o4en ende derr su su4e 4ers rs although pardoned
Prision Prisio n correccion correccional@ al@ suspensio suspension@ n@ an# #es&e #es&erro: rro: V 5he #ura& #ura&on on of he penal&es penal&es of prision prision correccional@ suspension an# #es&erro shall 2e from si monhs an# one #a1 o si 1ears@ ecep when suspension is impose# as an accessor1 penal1@ in which case@ is #ura&on shall 2e ha of he principal penal1: penal1: Arreso ma1or: V 5he #ura&on of he penal1 of arreso ma1or shall 2e from one monh an# one #a1 o si monhs: Arreso menor: V 5he #ura&on of he penal1 of arreso menor shall 2e from one #a1 o hir1 #a1s: 4on# o Beep he peace: V 5he 2on# o Beep he peace shall 2e re>uire# o coer such perio# of &me as he cour ma1 #eermine:
Accessory !enales
6 fold rule8 the ma-imum duraon of the convict0s sentence shall not be more than 6 mes the length of me corresponding to the most severe of the penales imposed upon him. the ma-imum duraon of the convict0s sentence shall in no case e-ceed 9 years 1emporary emporary dis5ualica dis5ualicaon on and suspe suspension, nsion, when impos imposed ed as acces accessory sory penales, have di4erent duraons ) they follow the duraon of the principal penalty $eserro is imposed in the following circumstances8 a serious physical inuries or death under e-ceponal circumstances spouse nding other spouse in pari delicto< b failure to give bond for good behavior a person ma*ing threat may be re5uired to give bond not to molest the person threatened, if not deserro<
c penalty for the concubine d in cases where the reducon of the penalty by one or more degrees results in deserro Bond to *eep the peace is not specically provided as a penalty for any felony and therefore cannot be imposed by the court. Ct is re5uired in Art 3N9 and not to be given in cases involving other crimes.
1he o4ender is entled to a deducon of fullme or 9K of the me of his detenon.
Ar: ,K: ,K: Peri Perio# o# of preen&e preen&e impri imprisonm sonmen en #e#uce# #e#uce# from from erm of imprisonmen imprisonmen: : V Ouali?ca&on which he ouisies es of eem eemp&o p&on n of he fo four urh h circu circumsa msance nce of Ar&cle Ar&cle D, are presen:V presen:V When all he con#i&ons con#i&ons re>uire# re>uire# in circums circumsance ancess Num2er H of Ar&cle D, of his Co#e o eemp from criminal lia2ili1 are no presen@ he penal1 of arreso ma1or in is maimum perio# o prision correccional in is minimum perio# shall 2e impose# upon he culpri if he shall hae 2een 'uil1 of a 'rae felon1@ an# arreso ma1or in is minimum an# me#ium perio#s@ if of a less 'rae felon1 felon1::
:e5uisites of Art 23 par 9 a< act caus causing ing the inury inury m must ust be law lawful ful b< act act pe perf rfor orme med d wK due due car care e c< inury inury was cau caused sed by mer mere e accid accident ent d< no faul faultt or iinte nteno non n to ccaus ause e inur inury y if these condions are not all present, then the 4 penales shall be imposed8 a< gra grave ve felony felony ) arres arresto to mayor mayor mama- to prision prision correcc correccional ional mi min n b< less grave grave felony felony ) a arres rresto to may mayor or min to arresto arresto ma mayor yor me med d
2 or 3 degrees lower if the maority of the condions for uscaon or e-empon in the cases provided in Arts. 22 and 23 are present. Ar: : : Succ Successie essie serice serice of senenc senence: e: V When he culpri culpri has has o sere wo wo or more pen penal&es@ al&es@ he shall sere hem simulaneousl1 if he naure of he penal&es will so permi oherwise@ he followin' rules shall 2e o2sere#9 In he imposi&on of he penal&es@ he or#er of heir respec&e seeri1 shall 2e followe# so ha he1 ma1 2e eecue# successiel1 or as nearl1 as ma1 2e possi2le@ shoul# a par#on hae 2een
'rane# as o he penal1 or penal&es ?rs impose#@ or shoul# he1 hae 2een sere# ou: "or he purpose of appl1in' he proisions of he ne prece#in' para'rap para'raph h he respec&e seeri1 of he penal&es shall 2e #eermine# in accor#ance wih he followin' scale9 D: !eah@ ,: Reclus ion pe perpeua@ G: Reclus ion emporal@ H: Prision ma1or@ J: Prision co correccional@ : Arreso ma1or@ : Arreso me menor@ : !es&erro@ K: Pe rp rpe u ua al a 2 2ss ol ol u ue #i #i s> s> ua ua llii ? ?cca& o on n@ D 5em empo pora rall a2 a2ss olu olue e #i #iss >u >ual ali? i?ca ca&o &on: n: DD DD:: Suspen Suspensio sion n from from p pu2l u2lic ic oce@ oce@ he he ri ri'h 'h o o o oe e a an# n# 2e o oe# e# ffor or@@ he ri'h ri'h o ffoll ollow ow a
Ar Ar:: : : Pe Penal nal1 1 o 2e imp impose ose# # upon a person person un#er un#er ei'heen ei'heen 1ea 1ears rs of a'e: a'e: V When When he ouals he same maimum perio#: Such maimum perio# shall in no case ecee# for1 1ears: In appl1in' he proisions of his rule he #ura&on of perpeual penal&es ( pena perpeua) shall 2e compue# a hir1 1ears: (As amen#e#):
Notes2 Art. MN applies to such minor if his applicaon for suspension of sentence is disapproved or if while in the reformatory instuon he becomes incorrigible in which case he shall be returned to the court for the imposion of the proper penalty.
Art. MN provides for 3 privileged migang circumstances Cf the act is aended by two or more migang circumstance and no aggravang circumstance, the penalty being divisible a minor over 2 but under 2N may sll get a penalty two degrees lower. under 2 but over P and has acted wK discreon8 3 degrees lower under 2N but over 28 2 degree lower
Ar: K: Penal1 Penal1 o 2e impose# impose# when h he e crime com commi3e# mi3e# is no wh wholl1 oll1 e ecusa2 cusa2le: le: V A penal1 lower 21 one or wo #e'rees han ha prescri2e# 21 law shall 2e impose# if he #ee# is no wholl1 ecusa2le 21 reason of he lacB of some of he con#i&ons re>uire# o +us&f1 he same or o eemp from criminal lia2ili1 in he seeral cases men&one# in Ar&cle DD an# D,@ proi#e# ha he ma+ori1 ma+ori1 of such con# con#i&ons i&ons 2e prese presen: n: 5he cour cours s shall shall impo impose se he pena penal1 l1 in he perio# which ma1 2e #eeme# proper@ in iew of he num2er an# naure of he con#i&ons of eemp&on presen or lacBin':
!enalty to be imposed when the crime commied is not wholly e-cusable
&a-imum duraon of the convict0s sentence8 6 mes the most severe penalty &a- period shall not e-ceed 9 years Subsidiary imprisonment ) this shall be e-cluded in compung for the ma-imum duraon -ample8 Ruan has 2 sentences of M months and 2 day each and a ne of 2. Ie was not able to pay the ne. 1herefore, he must serve subsidiary penalty aEer 2N months and 6 days in ail.
Ar: D: D: 6ra#ua 6ra#uae# e# scale scales: s: V In he case in which he law law prescr prescri2e# i2e# a pena penal1 l1 lower lower or hi'her 21 one or more #e'rees han anoher 'ien penal1@ he rules prescri2e# in Ar&cle D shall 2e o2sere# in 'ra#ua&n 'ra#ua&n' ' such penal1: 5he lower or hi'her penal1 shall 2e aBen from he 'ra#uae# scale in which is comprise# he 'ien penal1: 5he cours@ in appl1in' such lower or hi'her penal1@ shall o2sere he followin' 'ra#uae 'ra#uae# # scales9 SCALE NO: D D: !eah@ ,: Reclus ion pe perpeua@ G: Reclus ion emporal@ H: Prision ma1or@ J: : :
Prision co correccional@ Arreso ma1or@ !es&erro@
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: Arreso me menor@ K: Pu2lic censure@ D: "ine: SCALE NO: , D: Pe rp rp e e u ua al a a2 2s o oll u ue #i #i s> s>ua lili ?c ?ca & &o on n@@ ,: 5e mp mpo rra a l a2s ol ol u u e #i s> s>ua lili ?c ?c a& a& o on n G: Susp Suspen ensio sion n fro from m pu2 pu2lic lic o oce ce@@ he he ri'h ri'h o oe oe an an# # 2e 2e oe# for@ for@ he ri'h o follow a profession or callin'@ Pu2lic censure@ "ine:
H: J:
Ar Ar:: : Le' Le'al al perio# perio# of #ura #ura&on &on of #iis #iisi2l i2le e penal& penal&es: es: V 5he 5he le' le'al al perio# perio# of #ura #ura&on &on of #iisi2le #iisi2le penal&e penal&ess shall 2e consi#ere consi#ere# # as #ii#e# ino hre hree e pars@ pars@ formin' formin' hree perio#s@ he minimum@ he me#ium@ an# he maimum in he manner shown in he followin' a2le9 Ar: : : When h he e penal penal1 1 is a comple comple one comp compose# ose# of h hree ree #is& #is&nc nc pen penal&es: al&es: V In ca cases ses in which he law prescri2es a penal1 compose# of hree #is&nc penal&es@ each one shall form a perio#F he li'hes of hem shall 2e he minimum he ne he me#ium@ an# he mos seere he maimum perio#: Wheneer he penal1 prescri2e# #oes no hae one of he forms speciall1 proi#e# for in his Co#e@ he perio#s shall 2e #isri2ue#@ appl1in' 21 analo'1 he prescri2e# rules:
Ar: ,: Pref Preferenc erence e in he pa1men pa1men of he ciil lia2ili&es: lia2ili&es: V 5he ciil lia2 lia2ili&es ili&es of a perso person n foun# 'uil1 of wo or more ouialen o he een of such par&cipa&on: 'otes8 2. 1his ref refers ers to a person person who has parcipate parcipated d gratuitousl gratuitously y in the commission commission of a felony and and he is bound to ma*e restuon in an amount e5uivalent to the e-tent of such parcipaon 3. 1he third third person person must must be innoce innocent nt of the commiss commission ion of the crime crime otherwis otherwise e he would would be liable as an accessory and this arcle will apply
Ar: DD,: E&nc&on of ciil lia2ili1 lia2ili1:: V Ciil lia2ili1 esa2lishe# in Ar&cles D@ DD@ D, D,@@ an# DG of his Co#e shall 2e e&n'uishe# in he same manner as o2li'a&ons@ in accor#ance wih he Ar: D D:: O2li'a&on O2li'a&on o maBe maBe res resora& ora&on@ on@ repa repara&o ra&on n for #ama'es@ #ama'es@ or in#em in#emni?c ni?ca&on a&on for conse>uen&al #ama'es an# ac&ons o #eman# he same V $pon whom i #eoles: V 5he o2li'a&on o maBe resora&on or repara&on for #ama'es an# in#emni?ca&on for conse>uen&al #ama'es #eoles upon he heirs of he person lia2le: 5he ac&on o #eman# resora&on@ repara repara&on@ &on@ an# in#emni?ca&on liBewise #escen#s o he heirs of he person in+ure#:
1he heirs of the person liable has no obligaon if restoraon is not possible and the deceased leE no property "ivil liability is possible only when the o4ender dies aEer nal udgement. Cf the death of the o4ender too* place before any nal udgement of convicon was rendered against him, the acon for restuon must necessarily be dismissed.
Ar: DK: Share of each person ciill1 lia2le: V If here are wo or more persons ciill1 lia2le ffor or a felon1@@ he cours shall #eermine he amoun for which each mus respon#: felon1
proisions of he Ciil Law:
"ivil liability is e-nguished by8 2. paym paymen entt or perf perfor orma manc nce e 3. lo loss s of th the e tthi hing ng du due e 6. con condon donao aon n or rremi emissio ssion n of the the d debt ebt 9. conf confusion usion or or merger merger of the rights rights o off cre creditor ditor and and deb debtor tor . co m mp pe en n ssa a on on M. novaon %ther causes of e-nguishment of obligaons such as annulment, rescission, fulllment of a resolutory condion and prescripon are governed elsewhere in this code "ivil liability may arise from 2. "rime :!" 3. Breach of contract "" 6. 1orous act ) "" 1he civil liability from any of these is e-nguished by the same causes enumerated above 1he accused shall sll be liable for the payment of the thing stolen even if it is lost or destroyed
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Ar: DDG: DDG: O2li'a&on o sa&s sa&sf1 f1 ciil lia2ili1: V Ecep Ecep in case of e&nc&on of his ciil lia2ili1 as proi#e# in he ne prece#in' ar&cle he o
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