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+# Philippines: the missing constitutional and sentencing transitions
+
+26 October 2026. Followed the maintenance and writing guides, inspected the current profile, history and segment definitions. Baseline: 21 Philippine history entries; four articles. This pass adds three entries and four articles, revises three existing entries and preserves all score vectors and the current profile.
+
+## What fills the gap
+
+The existing 1993 restoration of capital punishment had no preceding 1987 constitutional suspension. The record also omitted the smaller-quantity reductions introduced by the same 1993 law, the 1994 Supreme Court interpretation in *People v. Simon*, and the practical relief in *Cruz* in 2000. Together these explain the intervening sentencing regime before the much harsher 2002 law.
+
+New entries and articles:
+
+- `philippines-constitutional-death-suspension-1987`, 2 February 1987: existing death sentences reduced to reclusion perpetua, and new death sentences prohibited unless Congress subsequently legislated for heinous crimes.
+- `philippines-simon-quantity-ruling-1994`, 29 July 1994: the Court resolves the overlapping penalty ranges, sets three lower marijuana quantity bands and applies the favourable amendment retrospectively.
+- `philippines-cruz-release-2000`, 19 January 2000: habeas corpus secures release after six years and three months for a 2.70-gram sale, beyond the applicable reduced maximum.
+
+The existing 2002 entry also receives an article. The 1993 description now covers both capital restoration and lower small-quantity penalties. The 2002 and 2006 dates are corrected from signature to effectivity, and the 2006 description removes an inaccurate attribution of its specific parole clause to life imprisonment.
+
+## Primary texts read
+
+1. [1987 Constitution](https://lawphil.net/consti/cons1987.html), Article III sections 12 and 19; Article XVIII sections 3 and 27. Existing laws continue unless inconsistent; death sentences already imposed become reclusion perpetua. The constitutional route for later congressional restoration remains explicit.
+2. [De Leon v. Esguerra](https://www.lawphil.net/judjuris/juri1987/aug1987/gr_l-78059_1987.html), G.R. L-78059, 31 August 1987. The majority dates effectivity to ratification on **2 February**, not the later proclamation. Some official explanatory pages use 11 February; the dissent also argues for that date. The entry follows the majority holding and the Constitution's immediate-ratification clause.
+3. [Batas Pambansa 179](https://lawphil.net/statutes/bataspam/bp1982/bp_179_1982.html), especially amended possession/use and cultivation provisions. Marijuana possession/use carries six years and one day to twelve years plus a fine; cultivation fourteen years and one day to life. These explain continuing severe imprisonment through the constitutional death suspension.
+4. [Republic Act 7659](https://lawphil.net/statutes/repacts/ra1993/ra_7659_1993.html), sections 13, 17 and 28. The quantity list includes 750 grams of marijuana and fifty grams of resin/oil; the lower band and aggravating exceptions must not be erased by summarising the law only as a capital restoration.
+5. [People v. Simon](https://lawphil.net/judjuris/juri1994/jul1994/gr_93028_1994.html), G.R. 93028, 29 July 1994: factual background, part II's interpretation and final disposition. Four recovered bags totalled 3.8 grams, but the appeal concerned the sale of two bags. Do not describe all 3.8 grams as proved sold. The actual sentence is **six months to six years**, not the shorter sentence in a different case applying Simon. Below 250 grams the statutory principal penalty is six months and one day to six years; the indeterminate-sentence minimum can be lower. Footnote 52 gives publication on 16 December 1993 and effectivity on 31 December.
+6. [In re David Cruz](https://lawphil.net/judjuris/juri2000/jan2000/gr_137560_2000.html), G.R. 137560, 19 January 2000. Read the failed appeal, legal-aid background, quantity, time served and release order. The Court grants habeas corpus while rejecting the separate challenge to dismissal of the appeal. It does not acquit Cruz. Release is subject to another lawful cause of detention. Avoid choosing between the opinion's differing September 1993 conviction dates; the article uses the year.
+7. [Republic Act 9165](https://lawphil.net/statutes/repacts/ra2002/ra_9165_2002.html), sections 3, 5, 11, 15–16, 77, 82 and 100–102. Read the actual possession, supply, cultivation and use provisions. The LawPhil footer wrongly gives January 23 as the approval date; it is not relied on. A Senate search result identifies 7 June approval, but opening that page returned 403; it is only a corroborating lead, and neither signature date determines effectivity.
+8. [Nisperos v. People](https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/68767), G.R. 250927, 29 November 2022: majority guidelines and footnote 44 explicitly give publication in the Manila Times and Manila Standard on 19 June 2002 and effectivity on **4 July 2002**. Used for commencement, not presented as a marijuana case: the underlying prosecution concerns methamphetamine.
+9. [Republic Act 9346, Supreme Court E-Library](https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/245), full short Act. Section 2 distinguishes reclusion perpetua from life imprisonment according to the offence's penalty terminology. Section 3's express no-parole wording names reclusion perpetua; the old entry incorrectly paraphrased it as covering people reduced to life imprisonment. Removing that attribution does not make a broader claim about parole eligibility under other laws. The E-Library also corrects transcription errors in LawPhil's passage date and Indeterminate Sentence Law number.
+10. [People v. Delima](https://lawphil.net/judjuris/juri2007/jul2007/gr_169869_2007.html), G.R. 169869, 12 July 2007: the penalty discussion expressly dates RA 9346's effectivity to **30 June 2006**, following the Act's publication requirement. Used for the date, not as a drug case. Other judgments sometimes loosely associate effectivity with 24 June signature; this entry follows the explicit later effective-date statement rather than the signature heading.
+
+Downloaded HTML and extracted text are retained in `tmp/history-philippines-sentencing-2026-10-26/`. Legal texts and judicial decisions are primary material; no article was written from a search summary.
+
+## Scores and scope
+
+All inherited `before` vectors and the current profile are unchanged. The 1987 suspension leaves six-to-twelve-year marijuana possession/use imprisonment and other long sentences, which remain in enforcement zero. In 1993/1994, death exposure for qualifying cannabis offences remains even while smaller quantities get reduced prison ranges. The 2002 tightening cannot take the already-zero possession, cultivation, sharing, consumption or enforcement segments below their floors. The 2006 abolition leaves long sentences for small possession and life for supply and cultivation, also within enforcement zero. Those legal changes therefore receive substantive `unscored` reasons; the individual Cruz release is an enforcement example, not a national legalisation or acquittal.
+
+This pass does not resolve whether the existing 1992 general compassionate-permit framework supported actual cannabis access from that date, or reconstruct the pre-1982 enforcement scores. Those require their own evidence and should not be silently inferred from these sentencing cases.
+
+## Validation
+
+History tests: 39 passed. Answer/profile-claim tests: 16 passed. The country-chain check reports no flagged transitions. A semantic preservation check verifies three additions, three revised existing entries, identical historical score vectors and a byte-identical current profile. The four articles have 350–500 words and four sections each; all cited sources and internal history links resolve. The full Astro build produced 4,177 pages. Browser verification checked the country score chart, its 24-entry History tab, the Simon article and its references, and the Philippines filter on `/history/`. Generated-page checks also verify all six touched event pages, source anchors, article links, decade pages and the unchanged current score of 1.