**Facts:** In June 2003, petitioner Michael Padua and Edgar Allan Ubalde were charged with violating Section 5, Article II of Republic Act No. 9165, the “Comprehensive Dangerous Drugs Act of 2002,” for unlawfully selling dangerous drugs in Pasig City. Before the Regional Trial Court (RTC), Branch 168, Pasig City, Padua, initially pleading not guilty, later changed his plea to guilty to avail of Section 70 benefits for first-time offenders under RA 9165. Consequently, the RTC found Padua guilty, sentencing him to an indeterminate sentence ranging from six (6) years and one (1) day of Prision Mayor as a minimum to seventeen (17) years and four (4) months of reclusion temporal as a maximum, besides a P500,000 fine.
Padua’s petition for probation was denied by the RTC, which cited Section 24 of RA 9165, disallowing probation for anyone convicted of drug trafficking. Padua’s motion for reconsideration was likewise denied. He then sought relief via a petition for certiorari with the Court of Appeals under CA-G.R. SP No. 86977, which was subsequently dismissed. Upon denial of his motion for reconsideration by the Court of Appeals, Padua elevated the issue to the Supreme Court, raising concerns over the denial of his probation and alleged violation of his rights under Administrative Order No. and Republic Act No. 9344, the “Juvenile Justice and Welfare Act of 2006.”
**Issues:**
1. Whether the Court of Appeals erred in dismissing Padua’s petition for certiorari challenging the RTC’s order denying his petition for probation.
2. Was Padua’s right, as a juvenile under RA 9344, violated?
3. Does Section 32 of A.M. No. 02-1-18-SC, the “Rule on Juveniles in Conflict with the Law,” apply in this case?
**Court’s Decision:**
1. The Supreme Court found that the Court of Appeals did not err in dismissing Padua’s petition for certiorari. The RTC acted within its jurisdiction and without grave abuse of discretion in denying the probation based on RA 9165, which expressly prohibits probation for individuals convicted of drug trafficking.
2. Padua’s contentions regarding his rights under RA 9344 were dismissed by the Court. The Act’s suspension of sentence provisions could not benefit Padua retrospectively since he was already over 21 years old at the time of the decision.
3. A.M. No. 02-1-18-SC’s Section 32, concerning the suspension of sentences, does not pertain to probation and, as such, does not apply to Padua’s case.
**Doctrine:** The Supreme Court reiterated the doctrine that any person convicted of drug trafficking or pushing, regardless of the penalty imposed, is not eligible for the benefits of the Probation Law or Presidential Decree No. 968, as amended, according to Section 24 of RA 9165. This decision underscores the clear distinction the law makes between users and traffickers/pushers of illegal drugs, emphasizing harsher penalties for the latter.
**Class Notes:**
– The case illustrates the non-applicability of the Probation Law (PD No. 968) to individuals convicted under certain sections of RA 9165, specifically those involved in drug trafficking or pushing (Section 24, RA 9165).
– It highlights the procedural steps and remedies sought by the accused in contesting a probation denial, including petitions for certiorari and motions for reconsideration with the Court of Appeals, leading to a final appeal with the Supreme Court.
– The ruling emphasized statutory interpretation principles, particularly the plain meaning rule, and how statutory provisions are to be applied based on their clear and unambiguous text.
– RA 9344 (Juvenile Justice and Welfare Act of 2006) and its provisions regarding the suspension of sentences are confined to the conditions and age limits specified therein, not affecting Padua due to his age at the time of the final judgment.
**Historical Context:** This case underscores the Philippine government’s stringent stance on drug trafficking and the legislative intent to differentiate between offenders based on their roles in drug-related activities (users vs. traffickers/pushers) through RA 9165 and subsequent legal frameworks concerning juvenile offenders. The decision not only reflects the judiciary’s interpretation and application of these laws but also contributes to the ongoing discourse on the treatment of minors within the criminal justice system, especially in the context of severe crimes like drug trafficking.
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