Cruz v. Correctional Institution for Women
REITERATIONFacts
The Antecedents: Petitioner Jesusa Cruz was convicted on March 31, 1992, for violation of Section 4, Article II of R.A. 6425 (Dangerous Drugs Act of 1972) for selling 5.5 grams of dried marijuana leaves. She was sentenced to life imprisonment. Procedural History: Her appeal was dismissed by the Supreme Court on March 1, 1993, in G.R. No. 106389, making her sentence final and executory. She was confined at the Correctional Institution for Women. The Petition: On August 6, 1996, petitioner filed a petition for habeas corpus, alleging she had served five and a half years of her sentence and arguing that the life imprisonment penalty was excessive given the small quantity of marijuana involved (5.5 grams). The Solicitor General interposed no objection to the favorable application of Section 20, Article IV of R.A. No. 6425, as amended by R.A. 7659.
Issue(s)
Whether the petitioner is entitled to the retroactive application of the reduced penalty provisions of Republic Act No. 7659 (RA 7659) through a writ of habeas corpus despite her conviction for selling 5.5 grams of marijuana having already become final and executory.
Ruling
The petition is meritorious. The petitioner is ordered released immediately, unless she is being detained on some other legal charges.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the petition for habeas corpus was meritorious because the beneficial effects of Republic Act No. 7659 (RA 7659) must be extended to the petitioner. Under RA 7659, the penalties prescribed by Republic Act No. 6425 (RA 6425) were modified such that for quantities of prohibited drugs less than 750 grams, the penalty is reduced from life imprisonment to a range of prision correccional to reclusion perpetua. Relying on the landmark cases of People v. Simon and People v. De Lara, the Court clarified that when the quantity of marijuana is less than 250 grams, the imposable penalty is prision correccional. Furthermore, the application of the Indeterminate Sentence Law (ISL) requires the penalty to be reduced to a term within arresto mayor as the minimum and the medium period of prision correccional as the maximum, provided there are no aggravating or mitigating circumstances. In the present case, since the petitioner sold only 5.5 grams of marijuana and had already served five and a half years (from February 2, 1991, to August 1996), the Court found that she had already exceeded the maximum period imposable under the amended law. Therefore, even though her original life sentence was final and executory, the more lenient provisions of the subsequent law must be applied to her favor, justifying her immediate release from confinement.
Main Doctrine
The beneficial effects of amendatory laws, such as R.A. 7659, which reduce penalties, should be extended to individuals whose sentences have become final, particularly when the penalty imposed is deemed excessive in light of the reduced penalties provided by the new law for the same offense.