Yes, threatening text messages are punishable as grave threats under Philippine law, and in many cases attract even heavier penalties than oral threats because they are considered “written threats” and are committed through information and communication technology (ICT).

The crime is primarily governed by Article 282 of the Revised Penal Code (RPC), as modified by Republic Act No. 10175 (Cybercrime Prevention Act of 2012) and jurisprudence of the Supreme Court.

Legal Basis

Article 282, Revised Penal Code (as amended)
Grave threats is defined as:

Any person who shall threaten another with the infliction upon the person, honor or property of the latter or of his family of any wrong amounting to a crime…

The law recognizes three modes of commission:

Threat demanding money or imposing any other condition (even if lawful), and the offender attains his purpose → penalty next lower in degree than that prescribed for the crime threatened.
If purpose not attained → penalty lower by two degrees.
Threat demanding money or imposing any other condition, but committed in writing or through a middleman → penalty imposed in its maximum period (regardless of whether purpose was attained or not).
Threat not subject to a condition → arresto mayor and fine not exceeding ₱100,000 (as updated by RA 10951).

The law explicitly states that when the threat is made in writing, the penalty is imposed in its maximum period — a rule that applies even if the threat is conditional.

Are Text Messages Considered “In Writing”?

Yes, categorically.

The Supreme Court has repeatedly ruled that text messages (SMS), messenger chats, Facebook messages, Viber, WhatsApp, Telegram, and even emails constitute written threats under Article 282.

Key decisions:

G.R. No. 207227, December 9, 2015 (People v. Takegawa) – threatening text messages were considered written threats; penalty imposed in maximum period.
G.R. No. 226093, July 23, 2018 – Supreme Court affirmed that threats sent via Facebook Messenger are written grave threats.
G.R. No. 240884, September 16, 2020 – threats via text message demanding money qualified as grave threats with the written-threat aggravation.
Numerous Court of Appeals and RTC decisions consistently treat electronic messages as written threats.

Therefore, any threat sent via text message automatically carries the aggravating circumstance of being “in writing,” resulting in the maximum penalty even if the threat was conditional and the sender did not attain his purpose.

Effect of the Cybercrime Prevention Act (RA 10175)

Section 6 of RA 10175 provides:

All crimes defined and penalized by the Revised Penal Code, as amended, and special laws, if committed by, through, or with the use of information and communications technologies shall be covered by the relevant provisions of this Act with penalties one degree higher.

Threats committed via text message, Facebook, or any online platform are punished one degree higher than the penalty under the RPC.

Practical effect:

A conditional grave threat to kill (originally reclusion temporal medium to maximum if purpose attained) becomes reclusion perpetua when sent via text message because of the combined effect of:

Written threat → maximum period under RPC
Use of ICT → one degree higher under RA 10175

This has been upheld in multiple cases since 2014.

Elements of Grave Threats That Must Be Proven

The offender threatens another person.
The threat is to inflict a wrong upon the person, honor, or property of the threatened person or his/her family.
The wrong threatened amounts to a crime (murder, homicide, physical injuries, rape, robbery, arson, slander, unjust vexation does NOT qualify).
The threat is communicated (actual receipt by the victim is required; sending to wrong number may not consummate the crime).
If conditional, there is a demand for money or imposition of any other condition.

The crime is consummated the moment the threat is received and understood by the victim — fear need not actually be produced (unlike coercion, which requires intimidation to produce fear).

Common Examples That Constitute Grave Threats Via Text

“Papatayin ko kayo ng buong pamilya niyo kung hindi niyo ako babayaran.”
“Isusumbong kita sa NBI at ipapakulong kita” — this is NOT grave threat because the act threatened (reporting to authorities) is not a crime.
“Babantaan kitang patayin hangga’t hindi mo binabayaran utang mo” → grave threat (threat to kill + demand for money).
“Puputukan ko bahay niyo mamayang gabi” → grave threat to commit arson or murder.
Sending photos of firearms with caption “Para sa’yo ‘to” → grave threat (Supreme Court has convicted on this basis).

What Does NOT Constitute Grave Threats

Vague or ambiguous messages (“Bahala ka sa buhay mo” is usually light threats or unjust vexation).
Threats to file a legitimate court case (“Idedemanda kita” is not a crime).
Threats to expose a lawful act.
Messages sent in jest, when context clearly shows it was a joke (burden is on the accused to prove).

Distinction from Related Crimes

Light Threats (Art. 283, RPC)
Threat to commit a wrong not constituting a crime (e.g., “I’ll slap you,” “I’ll embarrass you in public”). Penalty: arresto menor or fine.

Grave Coercion (Art. 286, RPC)
When the threat is used to compel the victim to do something against his will (whether right or wrong). If the victim is forced to act because of the threat, it may be coercion instead of threats.

Alarms and Scandals (Art. 155, RPC)
Only if the threat is discharged a firearm or causes public disturbance.

Psychological Violence under RA 9262 (Violence Against Women and Children)
Threatening messages sent to a spouse, ex-spouse, or dating partner can be charged as violation of RA 9262, which carries heavier penalties (prision mayor) and immediate protection orders.

Cyber Libel (if the message contains defamatory imputation together with threat).

Evidence Required for Conviction

Screenshots of the conversation (must show full context, date, time, and sender’s number/name).
Certification from the telco or platform (Globe, Smart, Facebook, etc.) to prove the account belongs to the accused.
Testimony of the complainant that the message was received and understood as a threat.
Printouts or forensic extraction of the phone (NLRC or PNP-ACG can do this).

The Supreme Court has ruled that screenshots, when properly authenticated, are admissible as electronic evidence under the Rules on Electronic Evidence (A.M. No. 01-7-01-SC).

Prescription Period

Grave threats prescribes in 10 years (RA 10951 amendment).
If charged with cybercrime enhancement, prescription is 15 years.

Penalty Summary Table (Most Common Scenarios)

Threat Type	Medium	Penalty (RPC only)	With RA 10175 (Cyber) Penalty
Threat to kill, conditional, purpose attained	Oral	Reclusion temporal	Reclusion perpetua
Threat to kill, conditional, purpose attained	Text/FB	Reclusion temporal maximum	Reclusion perpetua
Threat to kill, unconditional	Text/FB	Prision mayor	Prision mayor max to reclusion temporal medium
Threat to inflict serious physical injuries, conditional	Text	Prision correccional max to prision mayor min (max period)	Prision mayor medium to max

Conclusion

Threatening someone via text message is not only punishable as grave threats — it is punished more severely than oral threats because Philippine law and jurisprudence treat electronic messages as written threats and apply the cybercrime penalty enhancement.

The Supreme Court has consistently upheld convictions in such cases since the early 2010s, sending a clear message: threatening someone through text, Messenger, or any digital platform is a serious criminal offense that can result in years of imprisonment.

If you have received threatening messages, immediately preserve screenshots, file a blotter, and file the criminal complaint with the prosecutor’s office (preferably with a request for cybercrime investigation by the PNP Anti-Cybercrime Group or NBI Cybercrime Division). Protection orders under RA 9262 or a barangay protection order can also be obtained within hours.