G.R. No. 222187 , March 25, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. SIEGFREDO OBIAS, JR. Y ARROYO A.K.A. “BOBOY”, ACCUSED-APPELLANT.

FACTS

Accused-appellant Siegfredo Obias, Jr. was convicted by the Regional Trial Court for violations of Sections 11 and 12 of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from his illegal possession of 6.69 grams of methamphetamine hydrochloride (shabu) and drug paraphernalia. The Court of Appeals affirmed the conviction. The Supreme Court, in its main decision, dismissed the appeal and affirmed the penalties imposed: for illegal possession of dangerous drugs, an indeterminate sentence of twenty (20) years and one (1) day, as minimum, to thirty (30) years, as maximum, and a fine of P400,000.00; and for illegal possession of drug paraphernalia, six (6) months and one (1) day, as minimum, to two (2) years, as maximum, and a fine of P10,000.00.

ISSUE

Whether the indeterminate sentence imposed for illegal possession of dangerous drugs under Section 11(2) of R.A. No. 9165 , where the prescribed penalty is twenty (20) years and one (1) day to life imprisonment, was correctly determined in accordance with the Indeterminate Sentence Law.

RULING

Yes. Justice Peralta, in a Concurring Opinion, elaborated on the proper application of the Indeterminate Sentence Law to the penalty range under Section 11(2) of R.A. No. 9165 . The law prescribes a penalty of twenty (20) years and one (1) day to life imprisonment. Peralta explained that under the second sentence of Section 1 of the Indeterminate Sentence Law ( Act No. 4103 , as amended), for offenses punished under special laws like R.A. No. 9165 , the court must impose an indeterminate sentence where the minimum is not less than the minimum term prescribed by the law and the maximum is not more than the maximum fixed by the same law. While imposing a sentence of 20 years and 1 day to life imprisonment would technically comply, it would effectively nullify the benefits of the Indeterminate Sentence Law. This is because Section 2 of the same law expressly states it does not apply to persons convicted of offenses punished with life imprisonment. Consequently, an accused serving a maximum term of life imprisonment would be ineligible for parole. To give effect to the rehabilitative purpose of the Indeterminate Sentence Law, the Court correctly followed the doctrine in Argoncillo v. Court of Appeals. Thus, it imposed a minimum within the range (20 years and 1 day) and a definite maximum term not exceeding life imprisonment (30 years), which is still within the statutory range. This allows the accused, after serving the minimum and considering good conduct time, the possibility of parole and rehabilitation.