xxii[22] People v. Penillos, 205 SCRA 546, January 30, 1992; See also Administrative Circular
No. 6-92, which provides:
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For the guidance of all concerned, the reiteration and admonition by the Court on the same
subject in People vs. Penillos, 205 SCRA 546, January 30, 1992, are reproduced hereunder:
'As noted from the dispositive portion of the challenged decision, the trial court imposed the
penalty of reclusion perpetua or life imprisonment. Evidently, it considered the latter as the
English translation of the former, which is not the case. Both are different and distinct penalties.
In the recent case of People vs. Baguio, this Court held:
The Code does not prescribe the penalty of life imprisonment for any of the felonies
therein defined, that penalty being invariably imposed for serious offenses penalized not by the
Revised Penal Code but by special laws. Reclusion perpetua entails imprisonment for at least
thirty (30) years after which the convict becomes eligible for pardon. It also carries with it
accessory penalties, namely: perpetual special disqualification, etc. It is not the same as life
imprisonment which, for one thing, does not carry with it any accessory penalty, and for another,
does not appear to have any definite extent or duration.
As early as 1948, in People vs. Mobe, reiterated in People vs. Pilones and in the
concurring opinion of Justice Ramon Aquino in People vs. Sumadic, this Court already made it
clear that reclusion perpetua is not the same as imprisonment for life or life imprisonment. Every
Judge should take note of the distinction and this Court expects that, henceforth, no trial judge
should mistake one for the other. (Italics supplied).
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