Pandillerismo

Las pandillas y su regularización ante la ley

¿Qué es una pandilla?

Una pandilla es un grupo de adolescentes y/o jóvenes que se juntan para participar en actividades violentas y delictivas. Las pandillas están constituidas comúnmente entre niños y/o jóvenes de 13 a 20 años.

A través del tiempo este fenómeno social ha ido evolucionando y creciendo cada día más, por eso, los legisladoresse vieron en la necesidad de agregar esta figura como agravante en nuestro Código Penal, las pandillas hoy en día están constituidas por la mayoría de jóvenes que llegan a delinquir en algún momento, la pandilla puede ser un causante para que los jóvenes delinquen y vallan contra las buenas costumbres establecidas y aceptadas por la sociedad. A continuación analizaremos el concepto de pandilla y ladiferencia con la delincuencia organizada.

Los problemas del pandillismo o pandillerismo juvenil urbano dieron lugar a la reforma del Código Penal que introdujo dicha figura como agravante en la comisión de cualquier delito: hasta una mitad más de la pena aplicable a este. Por pandilla se entiende «la reunión habitual, ocasional o transitoria de tres o más persona que sin estar organizadascomo fines delictuosos, cometen en común algún delito» (Art. 164-bis). Existe una agravante de la agravante, a saber, el caso en que algún miembro de la pandilla sea o haya sido servidor público de cualquier corporación policíaca (Ibedem).

La jurisprudencia se ha ocupado en distinguir la pandilla de otras figuras penales y establecer el carácter heterónomo de aquella de aquella. En cuanto alprimer asunta, se afirma:

Hay notas distintivas entre el llamado pandillerismo y la asociación delictuosa. En el primero se trata de una reunión habitual, ocasional o transitoria de tres o más personas, que sin estar organizadas con fines delictuosos cometen comunitariamente algún ilícito; en cambio, la asociación delictuosa se integra también al tomar participación en una banda, tres o máspersonas pero precisa que aquella – la banda y los cierra» esta organizada para delinquir. Aquí de advierte la primera distinción entre una y otra de las figuras analizadas: la consistente en que el pandillerismo, no hay organización con fines delictuosos, y en la asociación si la hay. Pero todavía más. En esta segunda figura se requiere un régimen determinado con el propósito de estar delinquiendo,aceptado previamente por los componentes del grupo o banda; es decir, que debe de haber jerarquía entre los miembros que la forman, con el reconocimiento de la autoridad sobre de ello el que manda, quién tiene medio o manera de imponer su voluntad (A.D. 4379-72, Marcelo Alejandro Verdugo Cenizo 28 de febrero de 1973 unanimidad de 4 votos, componentes: Ernesto Aguilar Álvarez).

Por lo que toca elsegundo tema mencionado, la jurisprudencia ha manifestado reiteradamente que la pandilla no constituye un delito autónomo, sino que solo una circunstancia agravante del delito o los delitos acreditado en el proceso; se trata, pues de una calificativa heterónoma, según ha dicho – por ejemplo – El segundo Tribunal del Sexto Circuito:

El artículo 174 bis del código unitivo del distrito federal, asícomo los demás ordenamientos de las entidades de la república que contienen la misma disposición, no establece el pandillerismo como delito autónomo, sino como una circunstancia agravante de las infracciones que por naturaleza la admiten, pues su texto establece que se aplicara a los que intervengan «además de las penas que les correspondan por el o por los delitos cometidos…»

Lo que soloincrementan la sanción en relación directa con los ilícitos cometidos «en pandillas» (A.R. 609-95, Adelfo Poblano Peña, 24 de enero de 1996).

La figura penal de la pandilla fue más lejos de lo que se quiso originalmente. Se trato entonces de agravar la sanción aplicable a los miembros de grupos reunidos, con fines diferentes de la comisión de delito. Como señale, estos grupos se constituían ha…

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