Giving full meaning to juvenile justice

WHEN Congress enacted Republic Act 9344, also known as the Juvenile Justice and Welfare Act, it made a deliberate policy choice. The State would no longer treat children in conflict with the law as miniature adults deserving only punishment.

Instead, the law focuses on rehabilitation guided by the “best interests of the child” at the center of juvenile justice. Even when a child commits a grave offense, the law insists that society respond with restraint, structure, and the possibility of reform.

That philosophy was tested anew in a recent en banc ruling of the Supreme Court (People v. CICL XXX265302, G.R. No. 265302) promulgated on April 2, 2025, and released in January 2026.

The case involved an offender who was 15 years old at the time he committed qualified rape against a five-year-old child. By the time judgment was rendered, he was already an adult.

The crime was heinous. The facts were disturbing. And yet the Court was confronted with a difficult legal question: does the protection of RA 9344 still apply when the offender is no longer a child at the time of conviction? The Court answered in the affirmative.

While affirming the conviction, the Court ruled that because the accused was a child at the time of the offense, he was entitled to the automatic suspension of sentence under Section 38 of RA 9344.

More significantly, the Court clarified that the suspended sentence need not automatically end at age 21. To give real meaning to the law’s rehabilitative intent, suspension may be extended beyond that age if rehabilitation has not yet been achieved.

The case was remanded to the Regional Trial Court, not to commit the offender to an ordinary penal institution, but to place him in an agricultural camp or a similar facility designed for rehabilitation.

This clarification matters. Before this ruling, some courts treated the age-21 limit under Section 40 of RA 9344 as a hard stop. Once an offender reached that age, the benefits of suspended sentence were deemed to lapse regardless of whether rehabilitation had actually taken place.

The result was legal uncertainty and, at times, outcomes that undermined the very philosophy of the law.

The Court’s ruling aligns with earlier jurisprudence holding that the benefits of RA 9344 are substantive rights, anchored on the age of the offender at the time the crime was committed—not on how long the case took to resolve.

Delay in proceedings, often beyond the control of the accused, should not strip a child of protections the law expressly grants.

Of course, cases like this provoke unease. It is uncomfortable to speak of rehabilitation in the same breath as crimes as serious as qualified rape. Public instinct leans heavily toward punishment, especially when the victim is a child.

But the decision does not trivialize the offense. The conviction stands. Accountability remains. What the Court insists on is that accountability for children, even in the hardest cases must be shaped by a justice system that still believes in the possibility of reform.