Grave, Light anf Other Light Threats

Under the Revised Penal Code, there are three kinds of threats: grave threats (Article 282), light threats (Article 283) and other light threats (Article 285).

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.

 The records show that at around 7:30 in the evening, Julia Denido left her house to go to the barangay hall to report the mauling of her husband which she witnessed earlier at around 4:00 oclock in the afternoon. On her way there, petitioner confronted her and pointed a gun to her forehead, while at the same time saying Saan ka pupunta, gusto mo ito? Considering what transpired earlier between petitioner and Julias husband, petitioners act of pointing a gun at Julias forehead clearly enounces a threat to kill or to inflict serious physical injury on her person. Actions speak louder than words. Taken in the context of the surrounding circumstances, the uttered words do not go against the threat to kill or to inflict serious injury evinced by petitioners accompanying act.

Given the surrounding circumstances, the offense committed falls under Article 282, par. 2 (grave threats) since: (1) killing or shooting someone amounts to a crime, and (2) the threat to kill was not subject to a 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. 

source: 

Ronnie Caluag vs People of The Philippines, GR G.R. No. 171511 (March 4, 2009 – Second Division)

Rem Notes:
Threat (with or without condition) = Crime = "Grave Threat"

Threat (with condition) = Not a Crime = "Light Threat"
Threat (as specified) = Not a Crime = "Other Light Threat"

1. drawing of weapon
2. in the heat of anger, orally threaten and did not persist