Udk 15368; (September, 2021) (Digest)
G.R. No. UDK-15368, September 15, 2021
Gil Miguel, Petitioner, vs. The Director of the Bureau of Prisons, Respondent.
FACTS
Petitioner Gil Miguel was charged with and convicted of Murder by the Regional Trial Court of Quezon City, sentenced to reclusion perpetua, and delivered to the National Bilibid Prison on January 15, 1994. His conviction was affirmed by the Supreme Court on March 7, 1996. On August 19, 2015, Miguel filed a Petition for the Issuance of a Writ of Habeas Corpus, alleging his continued detention lacked legal basis. He argued that under Republic Act No. 10592 (the Good Conduct Time Allowance or GCTA Law), he had already served 38 years, 10 months, and 1 day. He further posited that Article 70 of the Revised Penal Code caps the duration of reclusion perpetua at 30 years, meaning he had served beyond the maximum and should be released.
ISSUE
Whether the Writ of Habeas Corpus may be issued in favor of petitioner Gil Miguel.
RULING
The Supreme Court dismissed the petition. First, the Court noted petitioner’s failure to observe the principle of hierarchy of courts, as the petition should have been filed with the Regional Trial Court absent special reasons for direct resort to the Supreme Court. On the merits, the Court held the petition lacked merit. Petitioner was not entitled to the benefits of the GCTA Law because its provisions expressly exclude persons charged with or convicted of heinous crimes. Murder is defined as a heinous crime under the law, as it is mandatorily punishable by death under Republic Act No. 7659 (the Death Penalty Law). Furthermore, the Court rejected petitioner’s interpretation of Article 70 of the Revised Penal Code. The penalty of reclusion perpetua entails imprisonment for at least 30 years, after which the convict becomes eligible for pardon, but it does not mandate automatic release after 30 years. As of the date of the decision, petitioner had served only 27 years and 7 months of his sentence. Therefore, his continued detention was legal and justified, and the writ of habeas corpus could not be issued.