Case Summary (G.R. No. 108172-73)
Applicable Law
The key legal provisions in question are Article 27 (subsequently amended by R.A. No. 7659) and Article 65 of the Revised Penal Code, which outline the nature of penalties, specifically reclusion perpetua, and examines whether it should be classified as a divisible penalty.
Nature of Reclusion Perpetua
In its decision issued on May 25, 1994, the First Division of the Court evaluated the implications of R.A. No. 7659 in relation to reclusion perpetua. The law established that reclusion perpetua has a duration of twenty (20) years and one (1) day to forty (40) years. However, it noted that the amendment did not clarify whether reclusion perpetua should be deemed a divisible penalty, as no amendments were made to Article 76 concerning divisible penalties.
Division of Penalty Periods
The division of reclusion perpetua into three equal periods was presented:
- Minimum: 20 years and 1 day to 26 years and 8 months
- Medium: 26 years, 8 months and 1 day to 33 years and 4 months
- Maximum: 33 years, 4 months and 1 day to 40 years Given the aggravating circumstance of relationship in the case, the First Division determined a penalty of thirty-four (34) years, four (4) months, and one (1) day of reclusion perpetua.
Motion for Clarification
On June 28, 1994, the appellee filed a motion for clarification, requesting correction of the penalty details, a motion which went uncontested by the accused-appellant. The Court was subsequently tasked with reassessing whether the amendments to Article 27 had indeed changed the nature of reclusion perpetua into a divisible one.
Legislative Intent
Following a thorough review, the en banc court concluded that there was no explicit legislative intent to classify reclusion perpetua as a divisible penalty. This was underscored by the bicameral discussions surrounding the amendment, which highlighted that reclusion perpetua remained an indivisible penalty despite the changes instituted by R.A. No. 7659.
Context of the Amendment
R.A. No. 7659 was a consolidation of Senate Bill No. 891 and House Bill No. 62, addressing heinous crimes and affirmatively imposing penalties without introducing the concept of life imprisonment as a new penalty. During deliberations, Senator Tolentino articulated the need for distinctions in penalty gradations yet affirmed that reclusion perpetua should retain its classification as an indivisible penalty.
Impact of Classification
If reclusion perpetua were reclassified as a divisible penalty, it would conflict with the principles laid out in Article 63 of the Revised Penal Code, which governs t
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Case Overview
- The case involves the People of the Philippines as the plaintiff-appellee against Conrado Lucas y Briones as the accused-appellant.
- The resolution was promulgated by the Supreme Court en banc on January 9, 1995.
- The focal point of the case is the interpretation of the penalty of reclusion perpetua following the amendments introduced by R.A. No. 7659, particularly in relation to Article 27 of the Revised Penal Code.
Legislative Background
- R.A. No. 7659 amended Article 27 of the Revised Penal Code to fix the duration of reclusion perpetua at twenty (20) years and one (1) day to forty (40) years.
- Despite this amendment, there was no corresponding change to Article 76, which raises questions regarding the classification of reclusion perpetua as a divisible penalty.
- The amendment aimed to establish a framework for heinous crimes, introducing penalties without reinstating the death penalty.
Interpretation of Reclusion Perpetua
- The First Division concluded that reclusion perpetua is not a divisible penalty despite the duration being specified.
- Article 65 of the Revised Penal Code allows the division of penalties into three