PEOPLE vs. Lacson, October 7, 2003

FACTS: Petitioner asserts that retroactive application of penal laws should also cover procedures, and that these should be applied only to the sole benefit of the accused. Petitioner
asserts that Sec 8 was meant to reach back in time to provide relief to the accused in line with the constitutional guarantee to the right to speedy trial.

ISSUES:
1. Whether or not the 5 Associate Justices inhibit themselves from deciding in the Motion for Reconsideration given they were only appointed in the SC after his Feb. 19, 2002 oral arguments.

The rule should be applied prospectively. The court upheld the petitioners’ contention that while Sec.8 secures the rights of the accused, it does not and should not preclude the equally important right of the State to public justice. If a procedural rule impairs a vested right, or would work injustice, the said rule may not be given a retroactive application.

2. WON the application of the time-bar under Section 8 Rule 117 be given a retroactive application without reservations, only and solely on the basis of its being favorable to the accused.

The Court is not mandated to apply rules retroactively simply because it is favorable to the accused. The time-bar under the new rule is intended to benefit both the State and
the accused. When the rule was approved by the court, it intended that the rule be applied prospectively and not retroactively, for to do so would be tantamount to the denial
of the State’s right to due process. A retroactive application would result in absurd, unjust and oppressive consequences to the State and to the victims of crimes and their heirs.