Title
Angeles y Bombita vs. Director of New Bilibid Prison
Case
G.R. No. 117568
Decision Date
Jan 4, 1995
Rolando Angeles, convicted for selling 0.13g of shabu, sought habeas corpus under R.A. 7659's retroactive penalty reduction. The Supreme Court dismissed his petition as premature, noting parole eligibility and urging liberal treatment of similar cases.
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Case Digest (G.R. No. 117568)

Facts:

  1. Conviction and Sentence: Rolando Angeles y Bombita was convicted for the sale of methamphetamine hydrochloride (shabu) under Section 15, Article III of the Dangerous Drugs Act of 1972 (R.A. No. 6425). He was sentenced to life imprisonment and fined P20,000.
  2. Petition for Habeas Corpus: Angeles filed a petition for habeas corpus, invoking Republic Act No. 7659, which reduced the penalties under the Dangerous Drugs Act, and the retroactive application of the law as confirmed in People v. Simon.
  3. Quantity of Drugs: The offense involved the sale and delivery of 0.13 grams of shabu.
  4. Applicable Penalty: Under the amended law (R.A. No. 7659), the penalty for the offense was reduced to prision correccional. Applying the Indeterminate Sentence Law, the modified penalty would range from six months of arresto mayor as minimum to six years of prision correccional as maximum.
  5. Service of Sentence: Angeles had only served the minimum of his sentence at the time of the petition.

Issue:

  1. Whether Rolando Angeles y Bombita is entitled to immediate release through a writ of habeas corpus due to the retroactive application of R.A. No. 7659.
  2. Whether the petition for habeas corpus is premature given that Angeles had only served the minimum of his sentence.
  3. Whether the courts should adopt extraordinary measures to address the plight of prisoners convicted under the old penalties of the Dangerous Drugs Act.

Ruling:

  1. Dismissal of the Petition: The Supreme Court dismissed the petition for habeas corpus as premature since Angeles had only served the minimum of his sentence.
  2. Parole Eligibility: The Court noted that Angeles may be eligible for parole under Section 5 of the Indeterminate Sentence Law if he meets the qualifications.
  3. Extraordinary Measures: The Court directed all courts of competent jurisdiction to entertain petitions for habeas corpus from prisoners convicted under the old penalties of the Dangerous Drugs Act who have served the maximum of the newly prescribed penalties. Such petitions should be construed liberally, even if deficient in form, as long as they are sufficient in substance.
  4. Referral to CHR and PAO: The Court ordered that a copy of the resolution be furnished to the Commission on Human Rights (CHR) and the Public Attorney's Office (PAO) for their information and guidance.

Ratio:

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