TL;DR

The Supreme Court clarified that while being classified as a penal colonist grants certain privileges like sentence reduction, it is not automatic for life sentences. For colonists serving life sentences, a sentence reduction to 30 years requires explicit executive approval from the President. The Court also ruled that the retroactive application of Republic Act No. 10592, which enhances Good Conduct Time Allowance (GCTA), must be considered for potential sentence reduction, and trial courts are competent to re-evaluate sentences based on this law.

Colonist Status: A Path to Freedom or a Presidential Prerogative?

Boy Franco y Mangaoang, a prisoner serving a life sentence for kidnapping, petitioned for a writ of habeas corpus, seeking immediate release. Mangaoang argued that his colonist status and accumulated Good Conduct Time Allowance (GCTA), especially with the retroactive application of Republic Act No. 10592, meant he had already served his time. He believed that the ‘automatic reduction’ of a life sentence to 30 years for colonists, coupled with GCTA, should warrant his release. However, the Director of Prisons countered that sentence reduction for colonists serving life imprisonment necessitates executive approval from the President, a power constitutionally vested solely in the Chief Executive. This case thus hinges on whether the privilege of sentence reduction for colonists is truly ‘automatic’ or subject to the President’s power of executive clemency, and how Republic Act No. 10592 impacts sentence computation.

The Supreme Court began by examining the nature of colonist status. It affirmed that the Director of Prisons has the discretion to classify inmates as colonists based on good conduct and time served. Colonist status indeed comes with privileges, including additional GCTA and the ‘automatic reduction’ of a life sentence to 30 years, as outlined in Section 7 of the Bureau of Corrections Operating Manual. However, the Court emphasized that the term “automatic” in the context of sentence reduction for colonists is misleading. Referencing Act No. 2489, the Court underscored the requirement of “executive approval” for the modification of a life sentence to 30 years for colonists. This executive approval, the Court clarified, is not a mere formality but a crucial step that distinguishes the classification as a colonist from the actual reduction of sentence.

The Court cited Tiu v. Dizon, which explicitly states that the classification as a penal colonist precedes the executive approval. The act of classification by the Director of Corrections is distinct from and must be followed by presidential approval for the sentence reduction to take effect. This distinction is vital because, as the Court elaborated, reducing a life sentence is akin to a partial pardon, an act of clemency that falls squarely within the President’s constitutionally granted power under Section 19, Article VII of the 1987 Constitution. This constitutional provision explicitly empowers the President to grant reprieves, commutations, and pardons. The Court firmly rejected the petitioner’s argument that executive approval could be delegated, asserting that the President must act personally in matters of clemency, which cannot be delegated under the doctrine of qualified political agency.

Furthermore, the Supreme Court addressed the petitioner’s reliance on Cruz III v. Go. It clarified that Go’s release was not solely due to colonist privileges but primarily because of GCTA under Articles 70 and 97 of the Revised Penal Code. The Court then considered the impact of Republic Act No. 10592, which retroactively enhanced GCTA benefits. Acknowledging the ruling in Inmates of the New Bilibid Prison, Muntinlupa City v. Secretary De Lima, the Court recognized the retroactive application of R.A. No. 10592. This law significantly increased GCTA credits and expanded its applicability, potentially altering sentence computations. The Court highlighted that the Bureau of Corrections is mandated to assess and compute time allowances under R.A. No. 10592, emphasizing the role of the Management, Screening and Evaluation Committee (MSEC) in this process.

Ultimately, the Supreme Court concluded that while Mangaoang’s colonist status and GCTA are relevant, his immediate release based solely on colonist privileges without executive approval was not warranted. However, recognizing the retroactive effect of R.A. No. 10592 and the need to recompute GCTA, the Court partly granted the petition. It referred the case to the Regional Trial Court of Muntinlupa to determine the actual time served by Mangaoang, recompute his GCTA and other privileges under R.A. No. 10592, and ascertain if he is entitled to release based on the fully served recomputed sentence. This referral acknowledges the trial court’s competency in handling factual and legal determinations related to sentence adjustments, as previously recognized in In Re: Correction/Adjustment of Penalty Pursuant to [R.A.] No. 10951.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: In the Matter of the Petition for Writ of Habeas Corpus of Boy Franco y Mangaoang, G.R. No. 235483, June 08, 2020