- Petitioner
- People
- Respondent
- Maclang
- Citation
- G.R. No. 214218
- Court
- Supreme Court
- Division
- First Division
- Decided
- September 21, 2022
Whether prisoner Rolando V. Maclang, Jr. has fully served his reclusion perpetua sentence and is entitled to immediate release considering time…
Summary
Parents of Rolando V. Maclang, Jr., who was convicted of kidnapping for ransom and sentenced to reclusion perpetua, filed a habeas corpus petition claiming their son had fully served his sentence when time allowances for good conduct under RA 10592 are considered. The Court of Appeals denied the petition, ruling that he had only served 25 years and 7 months, insufficient for the 40-year duration of reclusion perpetua. The Supreme Court partially granted the petition, clarifying that while Rolando Jr. cannot avail of penal colonist benefits without presidential approval, RA 10592 benefits apply retroactively. Given that over 8 years have passed since the OSG's computation showing 30+ years served, the Court referred the case to RTC Muntinlupa to determine actual confinement time and whether immediate release is warranted. This case establishes important precedents on retroactive application of RA 10592, requirements for penal colonist benefits, and proper procedure for computing sentence duration in post-conviction habeas corpus proceedings.