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Elements of the crime of grave threats as defined in Article 282 of the

Revised Penal Code and penalized by its paragraph 2


(1) that the offender threatened another person with the infliction
upon his person of a wrong;
(2) that such wrong amounted to a crime; and
(3) that the threat was not subject to a condition.

Reyes v. People G.R. Nos. L-21528 and L-21529, March 28, 1969

Threats:
Declarations of an intention to inflict a future wrong upon the person,
honor or property of another or the latter’s family. The acts or words
must be so efficacious as to amount to moral pressure and thus
produces fear, or mental disturbance.

the threats were made "with the deliberate purpose of creating in


the mind of the person threatened the belief that the threat would
be carried into effect."

the threats were made deliberately and not merely in a temporary fit
of anger,

In grave threats, the wrong threatened amounts to a crime which


may or may not be accompanied by a condition. In light threats, the
wrong threatened does not amount to a crime but is always
accompanied by a condition. In other light threats, the wrong
threatened does not amount to a crime and there is no condition.

Article 285, par. 1 (other light threats) is inapplicable although it


specifically states, shall threaten another with a weapon or draw
such weapon in a quarrel, since it presupposes that the threat to
commit a wrong will not constitute a crime. That the threat to
commit a wrong will constitute or not constitute a crime is the
distinguishing factor between grave threats on one hand, and light
and other light threats on the other.

Caluag v People G.R. No. 171511, March 4, 2009

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