Case Digest (G.R. No. 182855)
Facts:
The case involves Mr. Alexander Adonis, represented by the Center for Media Freedom and Responsibility (CMFR) and the National Union of Journalists of the Philippines (NUJP), as the petitioner, and Superintendent Venancio Tesoro, the Director of Davao Prisons and Penal Farm, as the respondent. The events leading to this case began when Adonis was convicted of libel in Criminal Case No. 48679-2001 by the Regional Trial Court (RTC) of Davao City, Branch 17, on February 20, 2007. He was sentenced to an indeterminate prison term ranging from five months and one day to four years, six months, and one day. Following his conviction, Adonis began serving his sentence at the Davao Prisons and Penal Farm.
On December 11, 2007, the Board of Pardons and Parole (BPP) issued an order for the discharge on parole of several inmates, including Adonis. This order was received by the City Parole and Probation Office of Davao on May 2, 2008. Meanwhile, on January 25, 2008, the Supreme Court i...
Case Digest (G.R. No. 182855)
Facts:
Background of the Case:
- Alexander Adonis, represented by the Center for Media Freedom and Responsibility (CMFR) and the National Union of Journalists of the Philippines (NUJP), filed a Petition for the Issuance of the Writ of Habeas Corpus under Rule 102 of the 1997 Rules of Court.
- The petition sought to compel Superintendent Venancio Tesoro, Director of the Davao Prisons and Penal Farm, to bring Adonis before the Court and, alternatively, to apply Supreme Court Administrative Circular No. 08-2008, which allows for the imposition of a fine instead of imprisonment in libel cases.
Conviction and Imprisonment:
- Adonis was convicted of libel in Criminal Case No. 48679-2001 by the Regional Trial Court (RTC) of Davao City, Branch 17, for a case filed by then Representative Prospero Nograles.
- He was sentenced to an indeterminate penalty of five (5) months and one (1) day of arresto mayor maximum, as minimum, to four (4) years, six (6) months, and one (1) day of prision correccional medium, as maximum.
- Adonis began serving his sentence on February 20, 2007, at the Davao Prisons and Penal Farm.
Second Libel Case:
- A second libel case, Criminal Case No. 48719-2001, was filed against Adonis by Jeanette L. Leuterio, pending before the RTC of Davao City, Branch 14.
Parole and Administrative Circular:
- On December 11, 2007, the Board of Pardons and Parole (BPP) issued an order for the discharge on parole of seven inmates, including Adonis. This order was received by the City Parole and Probation Office of Davao on May 2, 2008.
- On January 25, 2008, the Supreme Court issued Administrative Circular No. 08-2008, which provided guidelines for the imposition of fines instead of imprisonment in libel cases.
Motions Filed by Adonis:
- On April 18, 2008, Adonis filed a Motion to Reopen Case (With Leave of Court) with the RTC Branch 17, seeking his immediate release and modification of his sentence to a fine under Administrative Circular No. 08-2008.
- On May 26, 2008, in Criminal Case No. 48719-2001, Adonis moved for provisional release, which was granted by Judge George Omelio. He was allowed to post bail, and the court ordered his release unless he was held for other crimes. However, the release was not effected.
Petition for Habeas Corpus:
- On May 30, 2008, Adonis filed the instant petition for habeas corpus, alleging unlawful restraint by the respondent.
- The respondent filed a Comment, and Adonis filed subsequent motions reiterating his prayers.
- On February 11, 2009, the Court was informed that Adonis had been released on December 23, 2008, after accepting parole conditions.
Issue:
- Whether the writ of habeas corpus should be issued to release Adonis from detention.
- Whether Administrative Circular No. 08-2008, which allows the imposition of a fine instead of imprisonment in libel cases, should be applied retroactively to Adonis’s case.
Ruling:
The petition was dismissed. The Court held that:
- The writ of habeas corpus is not applicable when a person is detained under a valid judgment, as in Adonis’s case.
- Adonis was serving a sentence for libel, and his detention was lawful. The pendency of another criminal case (Criminal Case No. 48719-2001) disqualified him from immediate release on parole.
- Administrative Circular No. 08-2008 cannot be applied retroactively to Adonis’s case, as his conviction had already become final and executory, and he had commenced serving his sentence.
Ratio:
- (Unlock)