The story · written by gpt-6,
In July 1994, the Philippine Supreme Court reduced Martin Simon’s life sentence for selling marijuana to an indeterminate prison term of six months to six years.[1] His case established how courts should apply the new law’s lower sentences to small quantities, including offences committed before the amendment.[1]
A small sale had brought a life sentence
Simon was prosecuted after a police buy-bust operation in Guagua, Pampanga, in October 1988.[1] Officers recovered four tea bags containing a total of 3.8 grams of marijuana.[1] The Court treated the appeal as concerning the sale of two bags; the other two had been seized separately from his possession.[1]
The trial court imposed life imprisonment and a ₱20,000 fine.[1] The Supreme Court upheld his conviction, rejecting his challenge to the prosecution’s evidence, but a change in the law required it to reconsider his punishment.[1]
Restoring death also lowered small-quantity sentences
The 1993 amendment restored capital punishment for specified drug offences involving at least 750 grams of marijuana.[2] Below that quantity, it prescribed a lower range depending on weight.[2]
The text nevertheless used the same severe prison penalty, reclusion perpetua, both at the top of the lower range and at the bottom of the capital range.[1][2] The Court resolved that overlap in the defendant’s favour, holding that the lower range should stop at reclusion temporal, a fixed-term prison penalty.[1]
The Court divided smaller amounts into three bands
The ruling allocated marijuana below 250 grams to prision correccional, a penalty lasting six months and one day to six years.[1] The next band covered 250–499 grams, and the highest noncapital band covered 500–749 grams.[1] Sentencing circumstances and the rules for indeterminate sentences still affected an individual’s final term.[1]
For Simon, the resulting sentence ran from a six-month minimum to a six-year maximum.[1] The Court also explained that the amended law attached a fine to the reclusion-perpetua-to-death band, rather than these lower bands.[1]
Earlier convictions could benefit
The Court applied the favourable amendment retrospectively.[1] It said people whose convictions were already final could seek relief through habeas corpus, a court procedure for challenging unlawful detention.[1]
That route mattered in David Cruz’s case in 2000: the Court ordered his release after he had served longer than the reduced maximum for 2.70 grams.[3] The 2002 replacement drug law later imposed new possession bands and restored life-to-death exposure for unauthorised sales regardless of quantity.[4]
Listed for context. No score change is recorded for Philippines here.
References
- People v. Martin Simon y SungaSupreme Court of the Philippines · 1994 · G.R. 93028, 29 July 1994; part II, quantity bands, retroactivity and final disposition; footnote 52 on 31 December 1993 commencementarchived
- Republic Act No. 7659Congress of the Philippines · 1993 · Sections 13 and 17: marijuana and resin quantities, amended offences and lower-quantity penalties; section 28: publication conditionarchived
- In re: petition for habeas corpus of David Cruz y GonzagaSupreme Court of the Philippines · 2000 · G.R. 137560, 19 January 2000; 2.70 grams, six years and three months served, habeas corpus and release orderarchived
- Republic Act No. 9165 — Comprehensive Dangerous Drugs Act of 2002Congress of the Philippines · 2002 · Sections 3, 5, 11, 15–16, 77, 82 and 100–102archived
Checked. The date and the event were compared with a source that was read.