People v. Manalo
REITERATIONFacts
The Antecedents: Angelita Manalo y Dela Paz was charged with and convicted of the illegal sale of 0.02 grams of "shabu" and possession of prohibited drugs. The Regional Trial Court of Pasig, Metro Manila (Branch CLVIII) found her guilty beyond reasonable doubt for the illegal sale of 0.02 grams of "shabu" and sentenced her to life imprisonment, a fine of thirty thousand pesos, and costs. Procedural History: This Court affirmed the trial court's decision in G.R. No. 107623 on February 23, 1994. The accused moved for reconsideration, and subsequently filed an addendum praying for the retroactive application of Republic Act 7659, which would reduce her penalty. The Court denied the motion for reconsideration, noting that the addendum was filed after the decision had attained finality. The Petition: On July 29, 1994, this Court interpreted and reconciled conflicting provisions of R.A. 7659 in People v. Martin Simon. Pursuant to this ruling, the Court treated the accused-appellant's addendum to her motion for reconsideration as a petition for a writ of habeas corpus.
Issue(s)
Whether the accused-appellant is entitled to the retroactive application of the reduced penalties under Republic Act 7659 despite the finality of the judgment. What is the proper penalty to be imposed for the illegal sale of 0.02 grams of "shabu" considering the provisions of Republic Act 6425, as amended by Republic Act 7659, and the Indeterminate Sentence Law.
Ruling
The Court affirmed the conviction of Angelita Manalo y Dela Paz for the sale of 0.02 grams of "shabu" but modified the penalty. The imposable penalty was adjusted to an indeterminate sentence of SIX (6) MONTHS OF ARRESTO MAYOR, as the minimum, to FOUR (4) YEARS AND TWO (2) MONTHS OF PRISION CORRECTIONAL, as the maximum.
Ratio Decidendi
On the issue of retroactive application of Republic Act 7659: The Court held that even if a judgment has become final and executory, a petition for a writ of habeas corpus may be treated to seek relief under reduced penalties imposed by Republic Act 7659. This is based on the pragmatic consideration that judicial authorities should provide relief when a new law reduces the penalty for the offense. The Court explicitly stated that "practice, procedure and pragmatic considerations would warrant and necessitate the matter being brought to the judicial authorities for relief under a writ of habeas corpus." This approach allows for the modification of penalties even in cases where the judgment has already attained finality, provided the new law offers a more lenient penalty. On the proper penalty for illegal sale of 0.02 grams of "shabu": The Court determined that the proper penalty, pursuant to the second paragraph of Section 20 of R.A. 6425, as amended by Section 17 of R.A. 7659, is prision correccional. In consonance with the doctrine laid down in People v. Simon, the Indeterminate Sentence Law was applied. This resulted in an indeterminate sentence of SIX (6) MONTHS OF ARRESTO MAYOR, as the minimum, to FOUR (4) YEARS AND TWO (2) MONTHS OF PRISION CORRECTIONAL, as the maximum. This modification reflects the legislative intent to reduce penalties for certain drug offenses under the amended law.
Main Doctrine
Even if a judgment has become final and executory, a petition for a writ of habeas corpus may be treated to seek relief under a reduced penalty imposed by a new law, Republic Act 7659, if the judgment could be modified by such reduced penalties.