G.R. No. L-117376 December 8, 1994
IN THE MATTER OF THE PETITION FOR HABEAS CORPUS OF OSCAR DE GUZMAN, CHAIRMAN SEDFREY A. ORDOÑEZ, DIRECTOR EMMANUEL C. NERI AND THE COMMISSION ON HUMAN RIGHTS, petitioners, vs. DIRECTOR VICENTE VINARAO, BUREAU OF CORRECTIONS, respondent.

FACTS

Oscar de Guzman was convicted by the Regional Trial Court for selling two sticks of marijuana in violation of the Dangerous Drugs Act of 1972 and was sentenced to life imprisonment. The Supreme Court affirmed this conviction in People v. De Guzman. De Guzman had been serving his sentence since July 1984.
Subsequently, Republic Act No. 7659 , which amended the Dangerous Drugs Act, took effect on December 31, 1993. As interpreted by the Supreme Court in People v. Simon, this new law prescribed a significantly lower penalty for the possession or sale of marijuana weighing less than 250 grams, setting the imposable penalty within the range of prision correccional (6 months and 1 day to 6 years). Petitioners filed this habeas corpus petition, arguing that de Guzman’s continued detention under a now-inapplicable life sentence violated his rights, as he had already been imprisoned for over ten years, exceeding the maximum penalty under the new law.

ISSUE

Whether a writ of habeas corpus should be issued to order the release of Oscar de Guzman based on the retroactive application of a more favorable penal law.

RULING

Yes, the Supreme Court granted the petition and ordered the issuance of the writ. The legal logic is anchored on the constitutional and statutory principle that penal laws with provisions favorable to the accused, such as those which prescribe a lighter penalty, shall be given retroactive effect. This is a fundamental rule in criminal law designed to avoid excessive punishment.
The Court found that all procedural requirements for habeas corpus were satisfied: de Guzman was imprisoned, the detaining officer was identified, the place of confinement was specified, and the cause of detention was provided. On the substantive merits, the Court applied the ruling in People v. Simon, which clarified the penalties under R.A. No. 7659 . Since the quantity of marijuana involved in de Guzman’s case (two sticks) was indisputably less than 250 grams, the imposable penalty under the new law was only prision correccional. De Guzman had already served over ten years, which far exceeded the maximum six-year period under this new penalty range. Therefore, his continued detention under the old, more severe law had become illegal. The Court ordered his immediate release unless he was detained for another lawful cause and further directed the Bureau of Corrections to inventory all similarly situated prisoners for appropriate relief.