Facts:
Mauro P. Magtibay was convicted by the Regional Trial Court of Batangas City for violating Section 4, Article II of Republic Act No. 6425, known as The Dangerous Drugs Act of 1972, as amended. The conviction stemmed from a buy-bust operation conducted on August 21, 1989, where Magtibay was apprehended in the act of selling ten grams of dried marijuana leaves. He was sentenced to life imprisonment and had been in preventive detention at the New Bilibid Prison since his arrest, amounting to over six years of incarceration by the time the petition for habeas corpus was filed.
The petition for habeas corpus was initiated by the Commission on Human Rights and other petitioners, who sought the immediate release of Magtibay on the grounds that he had already served the applicable term of imprisonment for his offense. This argument was based on the provisions of Republic Act No. 7659, which amended the penalties for drug-related offenses, including those under the Dangerous Drugs Act.
Republic Act No. 7659 took effect on December 31, 1993, and it modified the penalties for drug offenses, particularly reducing the penalties for possession of marijuana when the quantity involved is less than 750 grams. Under the new law, the penalty for possession of less than 250 grams of marijuana was established as prision correccional, which is significantly less severe than the previous penalties outlined in the Dangerous Drugs Act.
Legal Issues:
- Whether Mauro P. Magtibay should be released from preventive detention based on the amended penalties under Republic Act No. 7659.
- The applicability of the new law to Magtibay's case, given that he had already served a term exceeding the maximum penalty under the amended law.
Arguments:
Petitioners' Argument: The petitioners contended that Magtibay had already served more time in preventive detention than the maximum penalty he could receive under the amended law. They argued that the changes in the law should apply retroactively, allowing for his immediate release.
Respondent's Argument: The Bureau of Corrections, represented by the Director Vicente Vinarao, did not oppose the petition for habeas corpus. The Office of the Solicitor General filed a manifestation indicating that they had no objection to Magtibay's release, acknowledging that he was eligible for immediate release based on the time served.
Court's Decision and Legal Reasoning:
The Supreme Court granted the petition for habeas corpus, ordering the immediate release of Mauro P. Magtibay. The Court reasoned that, based on the provisions of Article 29 of the Revised Penal Code, Magtibay had undergone preventive imprisonment for a period exceeding the maximum imprisonment he could be sentenced to under the amended law. The Court noted that the Solicitor General's lack of objection to the petition further supported the conclusion that Magtibay was entitled to release.
The Court dismissed the related case (G.R. No. 104992) as moot and academic, as the primary issue regarding Magtibay's detention had been resolved with the granting of the habeas corpus petition.
Significant Legal Principles or Doctrines Established:
Retroactive Application of Penal Laws: The case underscores the principle that amendments to penal laws can apply retroactively, particularly when they are favorable to the accused, as in the case of reduced penalties for drug offenses.
Habeas Corpus as a Remedy: The decision reaffirms the role of habeas corpus as a vital legal remedy for individuals who have been unlawfully detained or who have served more time than the law allows for their offenses.
Eligibility for Release Based on Time Served: The ruling clarifies that an individual who has served a period of preventive detention exceeding the maximum penalty under the applicable law is entitled to release, emphasizing the importance of adhering to statutory limits on imprisonment.