Lamen v. Director, Bureau of Corrections
REITERATIONFacts
The Antecedents: Petitioners filed a petition for the writ of habeas corpus to secure the release of Willy Bagawe y Pagalla, who was convicted of selling and delivering marijuana under Section 4, Article II of R.A. No. 6425, as amended. He was sentenced to life imprisonment and a fine of P20,000.00. The prohibited drugs involved were 3.5 grams of marijuana flowering tops, a marijuana cigarette butt, and 10 grams of marijuana flowering tops. Procedural History: The Supreme Court affirmed the trial court's judgment in a decision dated April 7, 1992, which became final on May 11, 1992. Willy Bagawe y Pagalla has been incarcerated since his arrest on April 14, 1987, and is serving his sentence at the New Bilibid Prisons. The Petition: Petitioners contend that based on the ruling in People v. Simon, the maximum term imposed on Bagawe should be reduced to two (2) years, four (4) months, and one (1) day of prision correccional, and since he has already served more than six years, he should be released. The Office of the Solicitor General agreed that Simon should apply but disagreed with the computation of the maximum penalty, recommending a penalty of six (6) months of arresto mayor as minimum to six (6) years of prision correccional as maximum, without fine.
Issue(s)
Whether Willy Bagawe y Pagalla is entitled to release from detention via a writ of habeas corpus. Whether the ruling in People v. Simon should be applied retroactively to reduce the sentence of Willy Bagawe y Pagalla, considering the finality of his conviction, and whether Article 22 of the Revised Penal Code can be invoked to modify a final and executory judgment.
Ruling
The petition is GRANTED. Willy Bagawe y Pagalla is ordered RELEASED from detention, unless for any other lawful cause his further confinement is warranted.
Ratio Decidendi
On the entitlement to release via habeas corpus: The Court granted the petition for habeas corpus. It acknowledged that while the judgment of conviction against Willy Bagawe y Pagalla had long become final and executory, the writ of habeas corpus serves as a remedy when a person is detained beyond the period prescribed by law or by a favorable statute. The Court found that Bagawe had undergone imprisonment for a period exceeding the maximum imprisonment that could have been properly imposed on him, taking into account the favorable statute, R.A. No. 7659. On the retroactive application of People v. Simon and Article 22 of the Revised Penal Code, and the modification of a final and executory judgment: The Court recognized that Article 22 of the Revised Penal Code operates to benefit Willy Bagawe since R.A. No. 7659 is favorable to him and he is not a habitual criminal. Following the principle established in People v. Simon, the penalty that could have been imposed under R.A. No. 6425, as amended by R.A. No. 7659, would have been prision correccional. Applying the Indeterminate Sentence Law, the indeterminate penalty would have ranged from six (6) months of arresto mayor, as minimum, to four (4) years and two (2) months of prision correccional as maximum. However, the Court clarified that Article 22 of the Revised Penal Code, while making penal provisions retroactive in favor of the accused, does not authorize a court whose sentence has become final and executory to make a substantial amendment to that sentence. Any such amendment would be null and void for lack of jurisdiction. The Court reiterated the principle that once a judgment becomes final and executory, it can no longer be altered or modified by the same court. This is a fundamental aspect of procedural law ensuring stability and finality in judicial decisions. Nevertheless, the Court distinguished between modifying a judgment and providing relief through habeas corpus. In this case, the Court held that the only means of giving retroactive effect to a penal provision favorable to the accused, when the trial judge has lost jurisdiction over the case due to finality, is through the writ of habeas corpus, as established in the case of Directo v. Director of Prisons.
Main Doctrine
While a court cannot alter a final and executory judgment, the writ of habeas corpus may be availed of to secure the release of a detention prisoner who has undergone imprisonment for a period exceeding the maximum penalty that could have been properly imposed under a subsequently enacted favorable penal statute, provided the prisoner is not a habitual criminal.