Cruz v. Correctional Institution

G.R. No. 125672 (September 27, 1996)

Facts:

Petitioner Jesusa Cruz, also known as Jesusa Mediavilla, was convicted on March 31, 1992, for violating Section 4, Article II of Republic Act No. 6425, otherwise known as the Dangerous Drugs Act of 1972, specifically for selling 5.5 grams of dried marijuana leaves. The Regional Trial Court of Iloilo City, Branch 33, imposed a life sentence on her, which was subsequently affirmed by the Supreme Court on March 1, 1993, in G.R. No. 106389, People vs. Jesusa Cruz. As a result, her life sentence became final and executory.

On August 6, 1996, Cruz filed a petition for habeas corpus through her appointed counsel, Atty. Mylene T. Marcia-Creencia. In her petition, she claimed to have served five and a half years of her life sentence as of the filing date. Cruz argued that the life imprisonment penalty was excessive given the small quantity of marijuana involved, which was only 5.5 grams, significantly less than the 750 grams threshold that would typically warrant such a severe penalty.

The Solicitor General, in a comment filed on August 30, 1996, expressed no objection to Cruz's application for relief under Section 20, Article IV of R.A. No. 6425, as amended by R.A. No. 7659.

Legal Issues:

1. Whether the petitioner, having served five and a half years of her life sentence for selling 5.5 grams of marijuana, is entitled to the benefits of the amended penalty provisions under R.A. No. 7659.
2. The applicability of the Indeterminate Sentence Law in light of the amendments made by R.A. No. 7659.

Arguments:

• Petitioner’s Argument:

  • Cruz contended that the life sentence imposed was excessive given the minimal amount of marijuana involved in her case. She argued that the amendments under R.A. No. 7659 should apply retroactively to her case, thereby allowing for a reduction in her sentence.

• Respondent’s Argument:

  • The Solicitor General did not oppose the petition and acknowledged the applicability of the amended provisions of R.A. No. 6425, indicating that the law should be interpreted in a manner that favors the petitioner.

Court's Decision and Legal Reasoning:

The Supreme Court granted the petition for habeas corpus, ruling that the petitioner was entitled to the benefits of the amended penalty provisions under R.A. No. 7659. The Court noted that the amendment, which took effect on December 13, 1993, modified the penalties for drug offenses, particularly reducing the penalties for cases involving less than 750 grams of prohibited drugs.

The Court referenced previous rulings, including Ordoñez vs. Vinarao and People vs. Simon, which established that for quantities of marijuana less than 250 grams, the appropriate penalty would be reduced to prision correccional. The Court further applied the Indeterminate Sentence Law, concluding that the maximum penalty for Cruz's offense should be reduced to a range that would allow for her immediate release, given that she had already served the maximum period for the crime for which she was convicted.

The Court emphasized that although Cruz's life sentence had become final, the beneficial effects of the amendment under R.A. No. 7659 should be extended to her, thereby ordering her immediate release unless she was being held for another legal charge.

Significant Legal Principles Established:

1. The amendments under R.A. No. 7659 apply retroactively to cases where the penalties have been modified, particularly in drug-related offenses.
2. The Indeterminate Sentence Law can be invoked to reduce the penalties for offenses involving small quantities of prohibited drugs, allowing for a more lenient application of justice.
3. The principle of favorability in penal laws dictates that when laws are amended to lessen penalties, such amendments should benefit the accused, even if the original sentence has become final.