Below is a broad, updated discussion of the law on qualified theft in the Philippines as it specifically relates to the theft of an amount around Nine Hundred Thousand Pesos (₱900,000). This write-up takes into account the Revised Penal Code (RPC), as amended (particularly by Republic Act No. 10951), relevant Supreme Court doctrines, and the basic rules on penalties and sentencing under Philippine law.

1. Legal Bases

Articles 308–310 of the Revised Penal Code (RPC):
- Article 308 defines theft in general.
- Article 309 classifies simple theft by the amount or value of the property stolen, and prescribes the corresponding penalties.
- Article 310 defines qualified theft and mandates the imposition of a penalty two degrees higher than that for simple theft under Article 309.
Republic Act No. 10951 (2017 Amendments):
This law adjusted the values/threshold amounts in various property crimes (theft, estafa, etc.) to keep pace with economic changes. The penalty brackets under Article 309 for theft were overhauled, including the bracket that covers the ₱600,000–₱1,200,000 range.
Indeterminate Sentence Law (Act No. 4103, as amended):
Governs how trial courts fix the minimum and maximum terms of imprisonment once they have identified the proper “penalty range” under the Revised Penal Code.

2. Simple Theft vs. Qualified Theft

A. Simple Theft (Article 309, as amended)

Under RA 10951, the penalties for theft now depend on the value of the property stolen, roughly summarized as follows (only the relevant brackets are highlighted here):

Over ₱600,000 but not exceeding ₱1,200,000
The penalty for simple theft is prisión mayor in its minimum and medium periods.

Prisión mayor runs from 6 years and 1 day to 12 years in its full range, but “minimum and medium periods” of prisión mayor effectively cover 6 years and 1 day up to 10 years of imprisonment.

B. Qualified Theft (Article 310)

Qualified theft is theft committed:

With grave abuse of confidence; or
By a domestic servant; or
Under other specific circumstances provided by law (e.g., theft of motor vehicles, large cattle, coconuts from a plantation, etc.).

Key provision: Article 310 mandates that “The penalty for qualified theft shall be two degrees higher than that prescribed for simple theft.”

Hence, if for ₱900,000 (which falls within ₱600,000–₱1,200,000) the penalty for simple theft is prisión mayor in its minimum and medium periods (6 years and 1 day to 10 years), then the penalty for qualified theft must be raised by two degrees from that baseline.

3. Determining the “Two Degrees Higher” Penalty

Under the Revised Penal Code’s hierarchy of penalties (in broad strokes):

Arresto mayor (1 month and 1 day to 6 months)
Prisión correccional (6 months and 1 day to 6 years)
Prisión mayor (6 years and 1 day to 12 years)
Reclusión temporal (12 years and 1 day to 20 years)
Reclusión perpetua (20 years and 1 day to 40 years)
Death (currently not imposed under Philippine law)

Each of these principal penalties is further subdivided into minimum, medium, and maximum periods. Moving “one degree” higher typically means going from one principal penalty to the immediately next (e.g., from prisión mayor to reclusión temporal). “Two degrees” up from prisión mayor normally places you at reclusión perpetua, at least if you consider the entire full ranges.

However, because the baseline (for theft of ₱900,000) is prisión mayor in its minimum and medium periods (roughly 6 to 10 years)—not the entire range of prisión mayor—courts often perform a more calibrated approach by looking at the overlap between periods. In many Supreme Court decisions applying Article 310, “two degrees higher” from prisión mayor (6y1d–12y) generally lands the penalty at reclusión perpetua. But if the baseline penalty is not the entire prisión mayor range but only the lower two periods (6y1d–10y), the typical result in practice is that the next two degrees lead the penalty at least into reclusión temporal—often in its higher periods—or reclusión perpetua, depending on how the court applies any mitigating or aggravating circumstances.

Common Judicial Approach

1st degree up from prisión mayor (or a major fraction of it) → reclusión temporal.
2nd degree up → reclusión perpetua.

In actual decisions, the Supreme Court may calibrate which “period” of reclusión temporal or reclusión perpetua applies. Nonetheless, reclusión temporal (12 to 20 years) and reclusión perpetua (20 to 40 years) are the standard two-step leaps above prisión mayor.

Bottom line: For qualified theft of ₱900,000, courts typically start from the “simple theft” bracket (prisión mayor min. and med.) and then move two degrees higher. This places the maximum penalty at least in the vicinity of reclusión temporal’s upper periods—possibly even reclusión perpetua—depending on the final analysis and the Indeterminate Sentence Law.

4. Role of the Indeterminate Sentence Law

Even after identifying reclusión temporal or reclusión perpetua as the appropriate “penalty range,” courts must apply the Indeterminate Sentence Law (ISL):

Maximum Term: Chosen within the correct penalty for the crime (here, two degrees higher than the baseline of prisión mayor min. and med.).
Minimum Term: Chosen from the penalty “one degree lower” than the maximum imposable penalty.

This can yield a sentencing formula such as:

Minimum: within the prisión mayor (max period) or reclusión temporal (min period), depending on how the court shifts the degrees;
Maximum: possibly within reclusión temporal (medium or maximum period) or up to reclusión perpetua.

Hence, the final sentence could look like, for example, “ten (10) years of prisión mayor as minimum to seventeen (17) years of reclusión temporal as maximum,” or it could extend higher if the court fixes the maximum in reclusión perpetua (which would eliminate parole under normal circumstances). The precise calibrations depend heavily on whether there are mitigating or aggravating circumstances, the presence of aggravating qualifiers (e.g., nighttime, burglary tools, etc.), and how the judge applies the periods.

5. Civil Liability and Other Consequences

Civil Liability (Restitution)
The accused, if convicted, must return or pay back the value of the property stolen (₱900,000) plus legal interest. The interest rate and date of accrual (usually from the finality of judgment) can vary under current jurisprudence but is commonly 6% per annum until fully paid.
Non-Bailable Nature (Depending on the Final Penalty)
- If the court’s assessment means that the penalty could be reclusión perpetua (or life imprisonment), that generally places the crime within the category of offenses that may be non-bailable if the evidence of guilt is strong.
- If, however, the maximum penalty the court applies is reclusión temporal (which is bailable), the accused can post bail subject to the judge’s discretion and standard procedures.
No Probation for Penalties Above 6 Years
Because the imposable penalty for qualified theft of ₱900,000 will exceed 6 years, probation cannot be granted under the Probation Law (Presidential Decree No. 968). Thus, a person convicted of this offense to a term above 6 years must serve the sentence in prison unless other post-conviction remedies apply.

6. Practical Illustration

Amount Stolen: ₱900,000
Baseline for Simple Theft (Art. 309): Prisión mayor (minimum and medium periods) = 6 years and 1 day to 10 years.
Two Degrees Higher for Qualified Theft (Art. 310): Potentially from reclusión temporal’s medium or maximum period up to reclusión perpetua, depending on how the court jumps the degrees and applies circumstances.
Resulting Indeterminate Sentence Example: A court might impose something like “11 years of prisión mayor as minimum to 17 years of reclusión temporal as maximum,” or even up to reclusión perpetua if aggravating circumstances and the standard penalty increment call for it.

7. Key Takeaways

Two-Degree Elevation: In the Philippines, if you take the penalty bracket for simple theft, qualified theft automatically raises it by two degrees.
Hefty Penalties Above ₱600,000: Once the value of the stolen property exceeds ₱600,000, the simple theft penalty is already significant (prisión mayor). Qualified theft magnifies it even further.
Possible Reclusión Temporal or Reclusión Perpetua: Depending on judicial interpretation and the specifics of the case, the maximum penalty can span from the upper range of reclusión temporal (up to 20 years) to reclusión perpetua (20 to 40 years).
No Probation: Because the penalty far exceeds six (6) years, the convicted offender is not eligible for probation.
Civil Liability: The offender must also pay back the full amount stolen (₱900,000), plus interest, as part of his or her civil obligation.

In sum, qualified theft of ₱900,000 in the Philippines attracts a significantly harsher penalty regime than simple theft of the same amount. The law deems abuse of confidence or the presence of a special relationship as a serious betrayal meriting two degrees higher than the otherwise applicable penalty under Article 309. Judges then fine-tune the final sentence via the Indeterminate Sentence Law, but even at its most lenient reading, a convicted person is almost certain to face a lengthy term of imprisonment (likely well above 10 years, potentially up to 20 years or even reclusión perpetua), alongside the civil obligation to return or pay for the amount stolen.