Case Digest (G.R. No. 251954)
Facts:
The case involves a petition for the issuance of a writ of habeas corpus filed by Atty. Rubee Ruth C. Cagasca-Evangelista, who represents her husband, Vincent B. Evangelista, and Raymundo Reyes, both of whom are inmates at the New Bilibid Prison in Muntinlupa City. The petition was filed on June 10, 2020, against Gerald Bantag, the Director General of the Bureau of Corrections, and all persons in custody of the inmates. Reyes and Evangelista were convicted on December 14, 2001, by Branch 103 of the Regional Trial Court (RTC) of Quezon City for violating Section 15, Article III of Republic Act No. 6425, as amended, due to the illegal sale of 974.12 grams of methylamphetamine hydrochloride, commonly known as shabu. They were sentenced to reclusion perpetua and ordered to pay a fine of Php 500,000. The conviction was affirmed by the Supreme Court on September 27, 2007. Over a decade later, the petitioner argued that the abolition of the death penalty and the repeal of the death ...
Case Digest (G.R. No. 251954)
Facts:
Conviction and Sentence:
- Raymundo Reyes and Vincent B. Evangelista were convicted on December 14, 2001, by Branch 103 of the Regional Trial Court (RTC) of Quezon City for violating Section 15, Article III of Republic Act No. (RA) 6425 (Dangerous Drugs Act of 1972), as amended by RA 7659. They were found guilty of illegally selling 974.12 grams of methylamphetamine hydrochloride (shabu) and were sentenced to reclusion perpetua and a fine of Php 500,000 each.
- The Supreme Court affirmed their conviction on September 27, 2007.
Petition for Writ of Habeas Corpus:
- Atty. Rubee Ruth C. Cagasca-Evangelista, the wife of Vincent Evangelista and counsel for both inmates, filed a petition for the issuance of a writ of habeas corpus. She sought:
- The release of Reyes and Evangelista from the New Bilibid Prison.
- A declaration that their continued detention under reclusion perpetua is illegal, arguing that the abolition of the death penalty under RA 9346 should revert the penalty for their crime to the original penalty under RA 6425 (6 years and 1 day to 12 years).
- Petitioner claimed that Reyes and Evangelista had already served 19 years and 2 months, which exceeds the maximum penalty under RA 6425, especially if Good Conduct Time Allowance (GCTA) under RA 10592 is applied retroactively.
- Atty. Rubee Ruth C. Cagasca-Evangelista, the wife of Vincent Evangelista and counsel for both inmates, filed a petition for the issuance of a writ of habeas corpus. She sought:
Legal Arguments:
- Petitioner argued that the abolition of the death penalty under RA 9346 should also repeal the penalty of reclusion perpetua for their crime, reverting it to the original penalty under RA 6425.
- She also contended that the inmates should benefit from GCTA under RA 10592, which would reduce their sentence further.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Writ of Habeas Corpus:
- The writ of habeas corpus is an extraordinary remedy used to inquire into the legality of a person's detention. It is not applicable when the detention is based on a valid and final judgment, as in this case.
Abolition of the Death Penalty:
- RA 9346 only abolished the death penalty and did not repeal the penalty of reclusion perpetua for heinous crimes under RA 7659. The penalty of reclusion perpetua remains valid and enforceable.
Good Conduct Time Allowance (GCTA):
- Under RA 10592 and its implementing rules, persons convicted of heinous crimes, including illegal sale of dangerous drugs exceeding 200 grams, are excluded from GCTA benefits.
Hierarchy of Courts:
- Direct recourse to the Supreme Court is improper when the issues involve factual determinations, such as the computation of sentences and eligibility for GCTA. Petitioners must follow the hierarchy of courts and file their petitions in the appropriate lower courts.