RPC supplements special penal laws
Article 10. Offenses not subject to the provisions of this Code. - Offenses which are or in the future may be punishable under special laws are not subject to the provisions of this Code. This Code shall be supplementary to such laws, unless the latter should specially provide the contrary.
Article 10 of the Revised Penal Code is composed of two clauses. The first provides that offenses which in the future are made punishable under special laws are not subject to the provisions of the RPC, while the second makes the RPC supplementary to such laws. While it seems that the two clauses are contradictory, a sensible interpretation will show that they can perfectly be reconciled.
[1] The first clause should be understood to mean only that the special penal laws are controlling with regard to offenses therein specifically punished. Said clause only restates the elemental rule of statutory construction that special legal provisions prevail over general ones.
[1] The first clause should be understood to mean only that the special penal laws are controlling with regard to offenses therein specifically punished. Said clause only restates the elemental rule of statutory construction that special legal provisions prevail over general ones.
[2] The second clause contains the soul of the article. The main idea and purpose of the article is embodied in the provision that the "Code shall be supplementary" to special laws, unless the latter should specifically provide the contrary. (Ladonga vs. People, G.R. No. 141066, 17 February 2005, 451 SCRA 673)
