Cagasca-Evangelista v. Bantag
REITERATIONFacts
The Antecedents: Petitioners, Raymundo Reyes and Vincent B. Evangelista, were convicted by the RTC of Quezon City for violation of Section 15, Article III of Republic Act No. 6425, as amended by Republic Act No. 7659, for the illegal sale of 974.12 grams of methylamphetamine hydrochloride (shabu). They were sentenced to suffer the penalty of reclusion perpetua and to pay a fine of Php 500,000.00 each. This conviction was affirmed by the Supreme Court. Procedural History: The Supreme Court affirmed the conviction of Reyes and Evangelista. The Petition: The wife of one of the inmates, Atty. Rubee Ruth C. Cagasca-Evangelista, filed a Petition for the Issuance of a Writ of Habeas Corpus, praying for the release of Reyes and Evangelista. Petitioner argued that the abolition of the death penalty under RA 9346 should revert the penalty for illegal drug sale to that originally imposed by RA 6425, and that the inmates had already served their sentences, considering the benefit of Good Conduct Time Allowance (GCTA) under RA 10592.
Issue(s)
Whether the petition for a writ of habeas corpus is the proper remedy, considering procedural requirements and the hierarchy of courts. Whether the abolition of the death penalty under RA 9346 affected the penalty for illegal sale of shabu, specifically whether reclusion perpetua remains the valid penalty. Whether the inmates, convicted of selling dangerous drugs, are entitled to GCTA under RA 10592, considering the nature of their crime and the relevant IRR.
Ruling
The Supreme Court dismissed the petition for the issuance of a writ of habeas corpus.
Ratio Decidendi
On the propriety of the petition for habeas corpus: The Court held that the petition must be dismissed on procedural grounds, including the lack of a verified declaration of electronic submission and the absence of a written explanation of service. More importantly, the petition disregarded the hierarchy of courts by filing directly with the Supreme Court. While the Court has concurrent jurisdiction to issue writs of habeas corpus, direct recourse is proper only for questions of law, not for issues requiring determination of facts, such as entitlement to GCTA. The petition's core issue, the release of the inmates based on alleged service of sentence with GCTA, necessitates factual determination, making it inappropriate for a direct Supreme Court petition. On the penalty for illegal sale of shabu: The Court clarified that RA 9346, which prohibited the imposition of the death penalty, only repealed or amended laws insofar as they imposed the death penalty. It did not repeal the penalty of reclusion perpetua imposed by RA 7659 for the illegal sale of dangerous drugs exceeding 200 grams. Therefore, the imposition of reclusion perpetua on Reyes and Evangelista remained valid. On the entitlement to GCTA: The Court ruled that individuals convicted of heinous crimes are excluded from the benefits of GCTA under RA 10592, as clarified by the 2019 Revised Implementing Rules and Regulations (IRR) of RA 10592. The Court affirmed that the distribution or sale of dangerous drugs, as committed by Reyes and Evangelista, constitutes a heinous crime, citing the Second Whereas Clause of RA 7659. Consequently, the inmates are not entitled to GCTA, and their continued detention is lawful.
Main Doctrine
A petition for a writ of habeas corpus will not prosper if the detention complained of is pursuant to a lawful judgment, and the issues raised require a determination of facts, such as entitlement to Good Conduct Time Allowance (GCTA), which are beyond the scope of habeas corpus and should be raised before lower courts. Furthermore, individuals convicted of heinous crimes are excluded from the benefits of GCTA.