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4. Interpretation of penal laws

a. CONCEPT

In case of doubt, penal law is to be construed strictly against the state. (People v. Madrigal, En Banc, G.R. No. L-2873, 28 February 1950)

“Criminal and penal statutes must be strictly construed, that is, they cannot be enlarged or extended by intendment, implication, or by any equitable considerations. In other words, the language cannot be enlarged beyond the ordinary meaning of its terms in order to carry into effect the general purpose for which the statute was enacted. Only those persons, offenses, and penalties, clearly included, beyond any reasonable doubt, will be considered within the statute’s operation. They must come clearly within both the spirit and the letter of the statute, and where there is any reasonable doubt, it must be resolved in favor of the person accused of violating the statute; that is, all questions in doubt will be resolved in favor of those from whom the penalty is sought.” (Statutory Construction, Crawford, pp. 460-462, cited in People v. Madrigal, supra.)

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