G.R. No. 178520 - AMA Computer College-East Rizal vs. Ignacio

Petition No. G.R. L-30364 by Angel C. Baking and Simeon G. Rodriguez;
Petition No. G.R. L-30603 by Jose Lava, Ramon Espiritu, Federico R. Maclang, Federico Bautista, Onofre Mangila, and Cesario Torres.

Petitioners had been in detention for more than eighteen (18) years under the custody of the Director of Prisons prior to the final resolution of their cases.

Criminal Prosecution and Final Judgment
On May 16, 1969, this Court rendered a final decision in People vs. Lava, et al.

Prior to this decision, on March 31, 1969, petitioners Baking and Rodriguez had already registered their habeas corpus petition, claiming a violation of their right to a speedy trial.

Petitioners asserted that, by serving more than eighteen (18) years in detention, they were entitled to deductions under Article 29 of the Revised Penal Code, which states that one-half of their preventive detention time should be credited to their sentence.
They further contended that benefited deductions under Article 97 for good conduct should apply for the entire detention period.

The petitioners relied heavily on the phrase “any prisoner” in the English text of Article 97 of the Revised Penal Code, arguing that the law makes no distinction between a detention prisoner and a convict already sentenced by final judgment.
They also invoked Section 5 of Act 1533 of the Philippine Commission, which provides for a credit for good conduct for detention prisoners who volunteer to perform labor, despite not demonstrating that they had complied with the required condition.

Procedural Posture
After the conviction, on May 24, 1969, Baking and Rodriguez moved for an early determination of their habeas corpus petition and for immediate release.
The Director of Prisons, through the Solicitor General, defended the non-application of Article 97 to detention prisoners, emphasizing that the statutory scheme only benefits convicts serving sentences.

Whether Article 97 of the Revised Penal Code, which provides for good conduct allowances, is applicable to detention prisoners or is limited exclusively to those serving a sentence by final judgment.
Whether the provisions of Article 29, providing a credit for preventive detention, and Section 5 of Act 1533 can be applied cumulatively to release petitioners who have served more than eighteen years in detention.
Whether the petitioners’ constitutional right to a speedy trial and due process has been violated by continuing their detention beyond the period necessary to serve their revised ten-year sentence.