G.R. No. 122668 October 3, 1996
Jessie de Leon, plaintiff-appellee, vs. People of the Philippines, accused-appellant.

FACTS

Jessie de Leon was convicted by the Regional Trial Court for violating Section 15, Article III of R.A. No. 6425 (The Dangerous Drugs Act of 1972) and was sentenced to life imprisonment and a fine. The Court of Appeals, on appeal, sustained his conviction but modified the penalty in light of the passage of R.A. No. 7659, imposing an indeterminate sentence of eight years of prision mayor, as minimum, to fourteen years and eight months of reclusion temporal, as maximum. De Leon filed a petition for review, not contesting his guilt but solely praying for a further reduction of this modified penalty.
Subsequent information revealed that the quantity of methamphetamine hydrochloride or “shabu” involved in the case was only 0.05 grams. The Office of the Solicitor General (OSG) filed a manifestation agreeing with the petitioner that a further penalty reduction was warranted, suggesting a specific lower range. This position was supported by a report indicating de Leon had already served a significant portion of the appellate court’s sentence.

ISSUE

Whether the penalty imposed by the Court of Appeals should be further reduced given the minimal quantity of the prohibited drug involved.

RULING

Yes, the penalty is further reduced. The Supreme Court affirmed de Leon’s conviction but modified the penalty. The legal logic rests on the application of the amendatory law, R.A. No. 7659, and the principle of proportionality in sentencing for drug offenses based on the quantity of the illicit substance. The Court found the case to be directly analogous to its precedents in People v. Manalo and Danao v. Court of Appeals, which both involved the sale of less than one gram of shabu (0.02 and 0.06 grams, respectively). In those cases, the Court imposed an indeterminate penalty of six months of arresto mayor, as minimum, to two years and four months of prision correccional, as maximum.
Following this established jurisprudence for minimal quantities, the Court imposed the same penalty on de Leon. Consequently, the Court resolved that if the reported service of four years, three months, and twelve days of the previously imposed sentence was accurate, de Leon should be immediately released, as this period already exceeds the new maximum penalty. The ruling emphasizes the necessity of calibrating penalties to the specific circumstances of the offense, particularly the minute drug weight involved.