De Leon v. People

G.R. No. 122668 (October 3, 1996)

Facts:

Jessie de Leon was charged with violating Section 15, Article III of Republic Act No. 6425, which pertains to the illegal sale of dangerous drugs. The case was tried in the Regional Trial Court of Pasig (Branch 167), where on March 5, 1993, de Leon was found guilty beyond reasonable doubt. He was sentenced to life imprisonment, a fine of P20,000.00, and subjected to all accessory penalties, along with the costs of the proceedings.

De Leon appealed his conviction to the Court of Appeals. On December 28, 1994, the Fourteenth Division of the Court of Appeals upheld his conviction but modified the sentence. In light of Republic Act No. 7659, which took effect on December 31, 1993, the appellate court reduced de Leon's sentence from life imprisonment to a range of eight years of prision mayor as the minimum to fourteen years and eight months of reclusion temporal as the maximum.

Subsequently, de Leon filed a petition for review on certiorari with the Supreme Court, not seeking to overturn his conviction but rather requesting a further reduction of the penalty imposed by the Court of Appeals. The Supreme Court reviewed the case, considering various submissions, including a letter from a paralegal worker at the New Bilibid Prisons, which indicated that the quantity of shabu involved in de Leon's case was only 0.05 grams and that he had already served four years, three months, and twelve days of his sentence, excluding good conduct time allowance.

Legal Issues:

1. Whether the penalty imposed by the Court of Appeals was appropriate given the quantity of the illegal substance involved.
2. Whether de Leon was entitled to a further reduction of his sentence based on the circumstances of his case.

Arguments:

• For De Leon: The petition for review argued that the penalty imposed by the Court of Appeals was still excessive considering the small quantity of shabu involved (0.05 grams). De Leon's counsel contended that a more lenient penalty should be applied, consistent with precedents set in similar cases.

• For the People of the Philippines (Office of the Solicitor General): The Solicitor General agreed with de Leon's position, suggesting that the penalty should be further reduced to an indeterminate sentence of six months of arresto mayor as minimum to two years and four months of prision correccional as maximum. This recommendation was based on the precedents of similar cases involving lesser quantities of illegal drugs.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed de Leon's conviction for the violation of Section 15, Article III of R.A. No. 6425 but modified the penalty. The Court applied the Indeterminate Sentence Law, concluding that the appropriate penalty for the sale of 0.05 grams of shabu was six months of arresto mayor as minimum to two years and four months of prision correccional as maximum.

The Court referenced previous rulings, specifically People v. Manalo and Danao v. Court of Appeals, which involved similar quantities of illegal drugs and resulted in lighter penalties. The Court noted that de Leon had already served a significant portion of his sentence, and if the time served was verified, he should be released unless held for other lawful reasons.

Significant Legal Principles or Doctrines Established:

1. The application of the Indeterminate Sentence Law allows for flexibility in sentencing, particularly in cases involving small quantities of illegal drugs.
2. The Court emphasized the importance of proportionality in sentencing, particularly in drug-related offenses, where the quantity of the substance plays a critical role in determining the appropriate penalty.
3. The decision reinforced the precedent that lighter penalties may be warranted for offenses involving minimal amounts of dangerous drugs, aligning with the principles of justice and rehabilitation.