People v. Saganib
REITERATIONFacts
The Antecedents: Samuel Saganib was convicted of Estafa under Article 315, paragraph 2(a) of the Revised Penal Code (RPC). He misrepresented himself as "Atty. Amos Saganib Sabling" to complainants, promising to facilitate the release of their friend from jail in exchange for P100,000.00 in attorney's fees. Despite the payment, the friend was never released and subsequently died in custody. Procedural History: On January 28, 2011, the Regional Trial Court (RTC) of Baguio City, Branch 3, found Saganib guilty and sentenced him to five (5) years of prision correccional as minimum to nine (9) years of prision mayor as maximum. The decision became final and executory on February 12, 2012. As of June 6, 2018, Saganib's prison record indicated he had served two (2) years, seven (7) months, and six (6) days, including earned Good Conduct Time Allowance (GCTA). The Petition: Saganib filed a Petition for Release before the Supreme Court, invoking Republic Act (R.A.) No. 10951 and the ruling in Hernan v. Sandiganbayan. He argued that under the new law, the penalty for Estafa involving P100,000.00 is reduced to arresto mayor in its maximum period to prision correccional in its minimum period. He sought the modification of his sentence and immediate release from confinement, asserting that he had already served the adjusted penalty.
Issue(s)
Whether the petitioner is entitled to the modification of his sentence and immediate release pursuant to Republic Act No. 10951 and the Hernan doctrine.
Ruling
The petition is GRANTED. The case is REMANDED to the Regional Trial Court of Baguio City, Branch 3, for the determination of the proper penalty and the petitioner's eligibility for immediate release.
Ratio Decidendi
On Issue 1: The Court held that while the petitioner is correct in invoking the retroactive application of Republic Act (R.A.) No. 10951, the Supreme Court is not the proper forum for the factual determination of his release. Citing In Re: Elbanbuena, the Court emphasized that determining entitlement to immediate release involves ascertaining the actual length of time served and the validity of Good Conduct Time Allowance (GCTA) credits. These are factual matters that the trial court is better equipped to handle than the high court. The Court reiterated the guidelines set in Elbanbuena, which mandate that such petitions must be filed with the Regional Trial Court (RTC) exercising territorial jurisdiction over the place of confinement. The guidelines provide a streamlined procedure, including a ten-day period for the Office of the Solicitor General (OSG) to comment and a ten-day period for the court to render judgment. This procedure ensures that the constitutional right to liberty is balanced with the need for accurate judicial verification of sentence completion. Consequently, the Court remanded the case to the RTC of Baguio City to apply the adjusted penalties under R.A. No. 10951 and determine if the petitioner has fully served his modified sentence.
Main Doctrine
The Court affirms that Republic Act No. 10951 has retroactive effect when favorable to the accused, even if the judgment is already final and executory. Following the Hernan and Elbanbuena precedents, the Court establishes that the proper venue for such petitions is the Regional Trial Court (RTC) of the locality where the convict is confined. This ensures a thorough verification of the actual length of time served and the validity of Good Conduct Time Allowance (GCTA) credits before release is ordered. This procedural rule prevents the Supreme Court from becoming a trier of facts in the administrative computation of prison sentences.