BY GEROME DALIPE IV
ILOILO City – The Supreme Court has ruled that imprisonment beyond the prescribed maximum penalty is not only cruel but also undermines the dignity of the detainee.
The tribunal underscored this in resolving the case of Jovelyn Antonio, who was convicted of qualified theft. Her case, however, prompted the tribunal to address the importance of upholding human dignity and ensure that sentences are served within the legal boundaries prescribed by law.
In affirming Antonio’s conviction for qualified theft, the Court also underscored the importance of adhering to legal boundaries when serving sentences.
In 2011, Antonio was convicted by the Regional Trial Court (RTC) of qualified theft for unlawfully taking money from her employer, GQ Pawnshop.
As the secretary, she was tasked with verifying the authenticity of pawned items. However, she exploited this role by using individuals to pawn fake items, resulting in the release of PHP 585,250 to the pawners.
The trial court sentenced Antonio to reclusion perpetua, which carries a minimum of 30 years in prison. She was committed to the Correctional Institution for Women on November 24, 2011.
In 2014, the Court of Appeals affirmed her conviction, and the case eventually reached the Supreme Court for review.
The tribunal upheld Antonio’s conviction, affirming that the prosecution successfully proved all the elements of qualified theft.
Under Article 308 of the Revised Penal Code (RPC), theft is defined as the act of taking another person’s property with the intent to gain, without violence, intimidation, or force, and without the owner’s consent.
However, the crime of theft is classified as qualified theft and carries a higher penalty when it is committed with grave abuse of confidence, as was the case with Antonio.
As an employee entrusted with verifying the authenticity of pawned items, her actions—using individuals to pawn fake items and causing the release of over PHP 585,000—exploited the trust her employer placed in her.
The court held that this breach of trust led to her conviction for qualified theft, with the penalty enhanced due to the gravity of the abuse of confidence in her position.
Despite this, the Supreme Court’s decision also addressed her sentence, ordering her immediate release after considering the time already served in detention.
The tribunal revisited the penalty that should be imposed on Antonio, determining that the appropriate punishment for her crime of qualified theft should be prisión mayor, as defined under the Revised Penal Code. This penalty carries a maximum imprisonment term of up to 10 years and 8 months.
Under Article 89, paragraph 2 of the RPC, criminal liability is extinguished upon the service of the sentence. Since Jovelyn had been detained since November 24, 2011, for almost 12 years, she had already served a period that exceeded the maximum penalty for her crime.
Given this, the Court emphasized the duty of the judiciary not only to impose appropriate sentences but also to ensure that detainees are released once they have served a period equal to or longer than the maximum penalty allowed by law.
This is in compliance with the United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules), which advocate for the humane treatment of detainees.
These rules assert that the primary purposes of imprisonment are to protect society and reduce recidivism, rather than subjecting individuals to excessive and unnecessary punishment.
“Those purposes can be achieved only if the period of imprisonment is used to ensure, so far as possible, the reintegration of such persons into society upon release so that they can lead a law-abiding and self-supporting life,” read the SC decision written by Associate Justice Mario V. Lopez.
As a result, the Supreme Court ordered Antonio’s immediate release, ensuring her detention was in line with both legal standards and international human rights principles.
By ordering her immediate release after she had already served her sentence, the Court reinforced its commitment to safeguarding human dignity and ensuring that justice is administered fairly and within the law./PN
