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People Vs Munoz People Vs Esparas People Vs Gatwad
People Vs Munoz People Vs Esparas People Vs Gatwad
Gatwad
Facts:
The accused was convicted of violating the Dangerous Drugs Act for unlawfully importing into
the Philippines heroin. The trial court sentenced the accused to suffer the penalty of imprisonment for
35 years of reclusion perpetua there being no aggravating or mitigating circumstance shown to have
attended in the commission of the crime.
Issues:
Whether or not the decision or penalty imposed by the trial court violated the accused
constitutional or legal right ?
Decision:
no constitutional or legal right of this accused is violated by the imposition upon him of the
corrected duration, inherent in the essence and concept, of the penalty.
Rationale:
As amended by RA 7659, the penalty of reclusion perpetua is now accorded a defined duration
ranging from 20 years and 1 day to 40 years. The Court held that in spite of the amendment putting the
duration of RP, it should remain as indivisible penalty since there was never an intent on the part of the
Congress to reclassify it into a divisible penalty. The maximum duration of reclusion perpetua is not
and has never been 30 years which is merely the number of years which the convict must serve in order
to be eligible for pardon or for the application of the 3-fold rule.
People vs. Esparas
Facts:
Esparas was charge with violation of RA 6425 as amended by RA 759 for importing into the
country 20 kg of shabu. As the accused remains at large up to the present time, the issue confronts the
Court is whether or not it will proceed to automatically review her death sentence.
Issues:
Whether the Court may proceed to automatically review Esparas' death sentence despite her
absence.
Decision:
Yes
Rationale:
The reimposition of the death penalty revived by the procedure by which the Supreme Court
reviews death penalty cases pursuant to the Rules of Court it remains automatic and continues to be
mandatory and does not depend on the whims of the death convict and leaves the SC without any
option. Any court decision authorizing the State to take life must be as error-free as possible. It is not
only within the power of the SC but also it is its duty to review al death penalty cases.
Sec. 8 of Rule 124 of the Rules of Court which authorizes the dismissal of an appeal when the
appellant jumps bail has no application to cases where the death penalty has been imposed.