Case Summary (G.R. No. 150194)
Initial Conviction
On October 28, 1988, Reynaldo Gonzales y Rivera was convicted by the trial court of illegal possession of firearms and attempted homicide. The trial court acquitted him of the attempted homicide charge due to the prosecution's failure to prove his guilt beyond a reasonable doubt. However, he was found guilty of illegal possession of firearms, resulting in a sentence of reclusion temporal ranging from 17 years, 4 months, and 1 day to 18 years, 8 months. No costs were declared in the judgment.
Affirmation by the Court of Appeals
The Court of Appeals subsequently affirmed the trial court's conviction on July 12, 1990. Following this affirmation, on November 13, 1990, Gonzales filed a petition for review on certiorari with the Supreme Court, seeking to reverse the appellate court's decision.
Legislative Changes and Modification of Sentence
While the Supreme Court case was pending, Republic Act No. 8294 was enacted, which amended the penalty provisions for the crime of illegal possession of firearms, effectively lowering the penalties prescribed therein. In a decision dated August 18, 1997, the Supreme Court upheld Gonzales's conviction but modified the penalty in accordance with the new law. The revised penalty was set to a minimum of four years and two months and a maximum of six years.
Calculation of Preventive Detention and Subsequent Developments
The Supreme Court noted that Gonzales had already served a period of nine years, nine months, and twenty-three days in detention, which exceeded the maximum imposed penalty for his offense. As a result, the Court ordered his immediate release unless he was being detained for another lawful cause.
However, it was later revealed by Action Officer Homobono R. Lachica, Jr. that the official records from the Bureau of Corrections indicated Gonzales had served only one month and twelve days. This discrepancy arose because after his conviction and bail bond forfeiture, he became untraceable until his subsequent arrest on September 16, 1993. He only entered the Bureau of C
...continue readingCase Syllabus (G.R. No. 150194)
Background of the Case
- Petitioner Reynaldo Gonzales y Rivera was convicted on October 28, 1988, for illegal possession of a firearm.
- He was also charged with attempted homicide; however, the prosecution failed to prove his guilt beyond a reasonable doubt for this charge.
- The court subsequently sentenced him to imprisonment for illegal possession of firearms, specifically to a penalty ranging from 17 years, 4 months, and 1 day to 18 years and 8 months of Reclusion Temporal, without any pronouncement regarding costs.
Court of Appeals Decision
- On July 12, 1990, the Court of Appeals affirmed the lower court's decision regarding the conviction for illegal possession of firearms.
- Following this affirmation, the petitioner filed a petition for review on certiorari on November 13, 1990, seeking to reverse the Court of Appeals' decision.
Legislative Changes and Subsequent Ruling
- While the petition was pending, Republic Act 8294 was enacted, which lowered the penalties for illegal possession of firearms.
- On August 18, 1997, the