People v. Labriaga
REITERATIONFacts
The Antecedents: Accused-appellant Rita Labriaga was apprehended on January 28, 1988, in Daraga, Albay, during a buy-bust operation where she was caught selling two tea bags of marijuana. At the time, Joel Labriaga was with her and found in possession of 3 grams of marijuana. Rita Labriaga was found in possession of 115 grams of marijuana. Procedural History: Charges were filed against them for violation of R.A. No. 6425 (Dangerous Drugs Act). The Regional Trial Court of Legazpi City, Branch 10, convicted Rita Labriaga of drug pushing and sentenced her to life imprisonment and a fine of P20,000.00. Joel Labriaga was convicted of illegal possession of marijuana and sentenced to 6 years and 1 day to 8 years imprisonment and a fine of P6,000.00. The Petition: Accused-appellant Rita Labriaga filed a motion for reconsideration with modification of sentence, praying for the retroactive application of R.A. No. 7659 and her release from confinement. She invoked the ruling in People v. Simon, arguing that if the quantity of marijuana is less than 250 grams, the penalty should be prision correccional. She contended that the 2 tea bags she possessed would amount to approximately 1.9 grams, thus warranting a reduction of her sentence from life imprisonment to prision correccional.
Issue(s)
Whether the motion for reconsideration, filed after the decision became final, can be treated as a petition for habeas corpus. Whether accused-appellant Rita Labriaga is entitled to release from confinement based on the retroactive application of R.A. No. 7659 and the ruling in People v. Simon.
Ruling
The Court granted the motion for reconsideration, treating it as a petition for habeas corpus, and ordered the release of Rita Labriaga from confinement, unless there is other lawful cause for her detention.
Ratio Decidendi
On the first issue: The Court held that while the appropriate remedy for Rita Labriaga would normally be to file a petition for habeas corpus since the decision was final, it would liberally apply the rules on habeas corpus in cases that are sufficient in substance. Citing its resolutions in Angeles v. Bilibid Prison and People v. Agustin, the Court treated the motion for reconsideration as substantial compliance with the rules for habeas corpus. On the second issue: The Court found merit in Rita Labriaga's motion. It noted that she had been confined since March 20, 1990, and had served a total of 6 years, 5 months, and 1 day, inclusive of good conduct time allowances. Considering the quantity of marijuana involved (even if the 115 grams were included, the total would still be less than 250 grams) and the period of her incarceration, which exceeded the maximum penalty of prision correccional (6 months and 1 day to 6 years) as established in People v. Simon for quantities less than 250 grams, the Court concluded that she should be released. The Court emphasized that the penalty imposable under R.A. No. 6425, as interpreted in light of People v. Simon and the quantity of drugs involved, would be prision correccional, and Rita Labriaga had already served more than this maximum penalty.
Main Doctrine
A motion for reconsideration, even if filed after the decision has become final, may be treated as a petition for habeas corpus if the accused has served more than the maximum imposable penalty for the crime, considering the retroactive application of amendatory laws.