**Ruben E. Tiu vs. Hon. Natividad G. Dizon, et al. (2018)**
### Facts:
Ruben E. Tiu was convicted on June 16, 2000, by the Regional Trial Court of Makati City, Branch 143, for selling and delivering 1,977 grams of methamphetamine hydrochloride without legal authority. He was sentenced to reclusion perpetua and fined P10,000,000. His conviction became final on July 29, 2004, after the Supreme Court affirmed it on March 10, 2004.
On March 24, 2009, the Board of Pardons and Parole (BPP) recommended executive clemency for Tiu. Subsequently, on June 3, 2010, President Gloria Macapagal-Arroyo conditionally pardoned him, subject to conditions that were never issued. Tiu’s requests for his pardon documents were denied thrice, on the grounds that his records were referred back to the BPP.
Additionally, Tiu claimed entitlement to sentence reduction citing his “colonist status” granted on December 21, 2011, which according to him, should reduce his life sentence to 30 years and apply Good Conduct Time Allowance (GCTA) as per RA 10592, enhancing GCTA provisions.
After failed attempts to secure his pardon documents and with his claims of entitlement to GCTA and reduced sentence under his colonist status, Tiu filed a petition for habeas corpus on July 7, 2014, seeking his release.
### Issues:
1. Whether Tiu’s conditional pardon without parole conditions granted was valid and enforceable.
2. Whether Tiu’s colonist status warranted an automatic reduction in his sentence.
3. The legality of Tiu’s further detention and his entitlement to release under habeas corpus.
### Court’s Decision:
The Supreme Court dismissed the petition, stating:
1. **Conditional Pardon Issue**: The conditional pardon was deemed incomplete and ineffective due to the absence of individual pardon papers specifying conditions, rendering Tiu’s claim invalid.
2. **Colonist Status and Sentence Reduction**: Tiu’s colonist status, although granted, did not alter his sentence as executive approval was essential for sentence modification, which he did not obtain.
3. **Legality of Detention**: Given that Tiu’s detention was by virtue of a final judgment and his non-compliance with prerequisites for executive clemency, his further detention was deemed lawful.
### Doctrine:
This case reaffirmed that execution and conditions of a pardon are purely executive acts beyond judicial scrutiny. It also highlighted that sentence modification under a colonist status requires executive approval, aligning with the principle that the pardoning power is exclusively vested in the President, which cannot be delegated.
### Class Notes:
– A pardon must be complete and communicated to the beneficiary with conditions explicitly stated to be valid.
– Conditional pardon is a contract between the executive and the convict, which must be fully executed to take effect.
– Modification of sentence through executive clemency, such as pardon or commutation, requires explicit executive approval.
– Good Conduct Time Allowance under RA 10592 and other laws requires proper computation and eligibility and cannot be presumed or self-applied by the convict.
### Historical Background:
Ruben E. Tiu’s case unfolded during significant policy changes (e.g., RA 10592 in 2013) regarding prison sentence computation in the Philippines, underscoring evolving legal interpretations of executive clemency, its conditions, and the importance of administrative processes in its execution. It illustrates the complex interplay between judicial finality and executive compassion, emphasizing strict compliance with procedural requisites for clemency.
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