People V Burton: Plaintiff-Appellee: Accused-Appellant: Facts

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o Second, the fine imposed upon appellant is the minimum

imposable of twenty thousand pesos (P20,000.00), whereas


People v Burton if he were penalized under the new law, he would have to bear
268 SCRA 531 | February 19, 1997 | Panganiban the minimum fine of P500,000.00.

PLAINTIFF-APPELLEE: People of the Philippines  Thus, retrospective application of Republic Act No. 7659, the
heinous crimes law would prove more burdensome upon the
ACCUSED-APPELLANT: William Robert Burton accused and would contradict the basic principle that all penal
laws shall be interpreted in favor of the accused.
FACTS:
 MAIN POINT:IN THE CASE AT BAR: The crime was committed on
British National William Burton was checked in at NAIA for his flight to Sydney, December 26, 1992 or about a year before Republic Act No. 7659
Australia. When his luggage bags were being examined through the x-ray machine, (which imposes the penalty of reclusion perpetua to death) came into
airport personnel saw that the sidings and bottom of the bags are darker in color effect on December 31, 1993. Retroactive application of said law
which made them doubt that something illegal was inside them. At the Customs would not be advantageous to the accused in view of the increased
Office at NAIA, his bags were slashed and there 5.6 kilograms of hashish (a range of penalty and conjunctive fine prescribed:
derivative of marijuana) was found. During investigation, 4 blocks of the same
substance was found to be hidden in his shoes. The Trial Court convicted Burton of o First, cases wherein life imprisonment is, unlike reclusion
attempting to transport prohibited drugs under Section 4, in relation to Section 21 of perpetua, does not carry accessory penalties. In the event
RA 6425. He was sentenced to life imprisonment and a fine of P20,000. that Republic Act No. 7659 is applied retrospectively to the
accused, he has to suffer not only reclusion perpetua but
In this current petition, Burton claims that that it was not proven that he knew that the
also the accessory penalties.
bags he had checked in at the airport contained a prohibited drug. The Court rejected
his defense and held that he did not successfully rebut the existence of animus
possidendi or knowledge of possession on his part when he was found to be in
possession of the hashish. The Court also held that the penalties imposed by the
Trial Court was correct because the retrospective application of Republic Act
No. 7659, the heinous crimes law would prove more burdensome upon the
accused and would contradict the basic principle that all penal laws shall be
interpreted in favor of the accused.

ISSUE? W/N BURTON PLACE IN EXPOST FATO LAW ?–

RULING: NO

 The crime was committed on December 26, 1992 or about a year


before Republic Act No. 7659 (which imposes the penalty of reclusion
perpetua to death) came into effect on December 31, 1993.

 Retroactive application of said law would not be advantageous to the


accused in view of the increased range of penalty and conjunctive
fine prescribed, where the quantity of prohibited drugs is 750 grams or
more.

o First, cases wherein life imprisonment is, unlike reclusion


perpetua, does not carry accessory penalties. In the event
that Republic Act No. 7659 is applied retrospectively to the
accused, he has to suffer not only reclusion perpetua but
also the accessory penalties.

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