De Guzman v. Vinarao
REITERATIONFacts
The Antecedents: Oscar de Guzman y Enriquez was charged with a violation of the Dangerous Drugs Act of 1972 (Republic Act No. 6425) for the willful and unlawful sale of two (2) sticks of marijuana. At the time of the offense, the law imposed severe penalties regardless of the quantity of the prohibited drug involved. Procedural History: The Regional Trial Court of San Jose City, Branch 39, convicted De Guzman and sentenced him to life imprisonment and a fine of P20,000. On appeal, the Supreme Court affirmed the conviction in toto in G.R. No. 76742. Subsequently, Republic Act No. 7659 was enacted, amending the penalties under the Dangerous Drugs Act based on the quantity of the drugs involved, effective December 31, 1993. The Petition: De Guzman, joined by the Commission on Human Rights (CHR), filed an original petition for habeas corpus directly with the Supreme Court. They argued that under the new law and the ruling in People v. Simon, the penalty for selling less than 250 grams of marijuana is now only prision correccional (6 months and 1 day to 6 years). Since De Guzman had been incarcerated since July 1984—a period exceeding ten years—his continued detention was alleged to be a violation of his basic human rights.
Issue(s)
Whether Oscar de Guzman is entitled to the writ of habeas corpus and immediate release due to the retroactive application of the reduced penalties under Republic Act No. 7659 as interpreted in People v. Simon, considering the quantity of marijuana involved and the duration of his imprisonment.
Ruling
The petition is GRANTED. Let a writ of habeas corpus issue immediately. The Director of the New Bilibid Prisons is commanded to execute the writ for De Guzman's discharge and submit an inventory of all other prisoners similarly situated within thirty days.
Ratio Decidendi
On Issue 1: The Court ruled that De Guzman is entitled to the benefit of the reduced penalty introduced by Republic Act No. 7659. Applying the interpretation in People v. Simon, the Court noted that if the quantity of marijuana involved is less than 250 grams, the imposable penalty is prision correccional, which ranges from six months and one day to six years. In this case, De Guzman was convicted for selling only two sticks of marijuana, which clearly falls within the lower threshold. Since the petitioner has been serving his sentence since July 1984, he has already been in prison for more than ten years, which is well beyond the maximum six-year limit of the new penalty. The Court emphasized that the writ of habeas corpus is the appropriate remedy for illegal confinement or detention where a person is deprived of liberty without lawful cause. Therefore, his continued detention constitutes a violation of his basic human rights, necessitating his immediate release from the National Penitentiary.
Main Doctrine
The writ of habeas corpus extends to all cases of illegal confinement or detention by which any person is deprived of his liberty. When a new law, such as Republic Act No. 7659, reduces the penalty for a crime and the prisoner has already served more than the maximum of the new imposable penalty, their continued detention becomes illegal. Under the principle that penal laws shall have a retroactive effect insofar as they favor the person guilty of a felony, the prisoner is entitled to immediate release from confinement.