Case Digest (G.R. No. L-30026)
Facts:
Mario Gumabon, Blas Bagolbagol, Gaudencio Agapito, Epifanio Padua and Paterno Palmares v. The Director of the Bureau of Prisons, G.R. No. L-30026, January 30, 1971, the Supreme Court En Banc, Fernando, J., writing for the Court.The five petitioners — Mario Gumabon, Blas Bagolbagol, Gaudencio Agapito, Epifanio Padua and Paterno Palmares — sought release by way of a petition for habeas corpus from detention under life sentences imposed for the so‑called complex crime of rebellion with multiple murder and other offenses. Gumabon pleaded guilty and was sentenced to reclusion perpetua on May 5, 1953; Bagolbagol was sentenced on January 12, 1954; Agapito and Palmares on March 8, 1954; and Padua on December 15, 1955. Each has been continuously imprisoned since these convictions and, by the time of the petition, had served more than thirteen years; the Solicitor General admitted these factual allegations in his answer.
After the petitioners’ convictions became final, this Court in People v. Hernandez, 99 Phil. 515 (1956), declared that the complexing of common crimes with rebellion is not supported by Article 134 of the Revised Penal Code — in short, that no such complex offense exists. That doctrine was reaffirmed in People v. Lava (L-4974, May 16, 1969). Petitioners contended that, in light of Hernandez and Lava, the maximum penalty for the offense they were convicted of could only have been prision mayor (twelve years), that they had already served more than that maximum, and that continued detention was therefore illegal.
The petition invoked, among other grounds, denial of equal protection and the retroactive effect of judicial decisions as part of the legal system (Art. 8, Civil Code) coupled with the retroactivity provision for penal laws (Art. 22, Revised Penal Code). The Court was asked to reconsider the earlier holding in Pomeroy v. Director of Prisons (107 Phil. 50, 1960), but resolved the petition without overruling Pomeroy. The Supreme Court granted the habeas corpus petition and ordered the petitioners released. Several justices filed a separate concurring op...(Subscriber-Only)
Issues:
- Is the writ of habeas corpus available to persons detained under a final judgment of conviction where the sentencing court had jurisdiction?
- May the Court apply retroactively its judicial ruling in People v. Hernandez (and its reaffirmation in People v. Lava) so as to reduce the effective penaI exposure of petitioners who were sentenced before those decisions, pursuant to Article 22 of the Revised Penal Code and Article 8 of the Civil Code?
- Does continuing to detain petitioners beyond the maximum penalty now recognized for their offense violate the consti...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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