Gumabon v. Director of Prisons -Crim Digest




Facts:
                Petitioner Mario Gumabon, after pleading guilty, was sentenced on May 5, 1953 to suffer reclusion perpetua for the complex crime of rebellion with multiple murder, robbery, arson and kidnapping. Petitioners Gaudencio Agapito, Paterno Palmares and Epifanio Padua, likewise pleaded guilty to the complex crime of rebellion with multiple murder and other offenses, and were similarly made to suffer the same penalty in decisions rendered, as to the first two, on March 8, 1954 and, as to the third, on December 15, 1955. The last petitioner, Blas Bagolbagol, stood trial also for the complex crime of rebellion with multiple murder and other offenses and on January 12, 1954 penalized with reclusion perpetua. Each of the petitioners has been since then imprisoned and served for more than 13 years by virtue of the above convictions.

Issue:
                Whether or not petitioners be given a retroactive effect with habeas corpus as appropriate remedy.

Held:
                Yes.

Ratio:
                In Director v. Director of Prisons, it was explicitly announced by the Court “that the only means of giving retroactive effect to a penal provision favourable to the accused… is the writ of habeas corpus.” While the above decision speaks of a trial judge losing jurisdiction over the case, insofar as the remedy of habeas corpus is concerned, the emphatic affirmation that it is the only means of benefiting the accused by the retroactive character of a favourable decision holds true. Petitioners clearly have thus successfully sustained the burden of justifying their release.

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