People v. Lucas

Summary

The Supreme Court En Banc resolved whether R.A. No. 7659's amendment fixing reclusion perpetua's duration at 20 years and 1 day to 40 years converted it from an indivisible to divisible penalty. Initially, the First Division held it became divisible with three periods, allowing for graduated application. However, the En Banc reversed this interpretation, finding no clear legislative intent to alter reclusion perpetua's traditional classification as indivisible. The Court emphasized that making it divisible would undermine Article 63's rules on applying indivisible penalties with aggravating/mitigating circumstances. The amendment merely clarified the existing jurisprudential maximum duration without changing the penalty's essential indivisible nature. This landmark decision preserved the traditional binary application of reclusion perpetua to death penalties in heinous crimes under the Revised Penal Code.