Facts:

The case revolves around Catalina Alberca y Bustillo, the petitioner and appellant, against The Superintendent of the Correctional Institution for Women, the respondent and appellee. This legal matter arose from events that transpired in the Philippines, specifically in the Municipal Court of Manila. On April 8, 1957, at 2:15 PM, an information was filed against the appellant, accusing her of theft involving a mechanical jack worth P120.00, owned by one Vicente Lim. The criminal charge included allegations of habitual delinquency, stating that the appellant had previously been convicted of theft five times within a ten-year span from her last release.

On the same day of filing, at 10:00 PM, Alberca was arraigned, pleaded guilty, and was immediately sentenced. The ruling imposed a penalty of 6 months and 1 day of prisión correccional along with an additional 10 years and 1 day of prisión mayor as a consequence of her habitual delinquency. After serving her sentence, on February

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Facts:

Background of the Case

• Catalina Alberca y Bustillo, the petitioner and appellant, was charged with the offense of theft before the Municipal Court of Manila.
• The theft involved a mechanical jack valued at ₱120.00, which belonged to Vicente Lim.
• The information charging her was filed on April 8, 1957, at 2:15 p.m., alleging that the crime was committed the previous day, April 7, 1957.

Criminal History and Allegation of Habitual Delinquency

• The charging document detailed that the appellant was a habitual delinquent having been previously convicted five times of theft.
• The record explicitly recited the dates when the previous offenses were committed, the corresponding judgment dates, the penalties imposed, and the dates of her release from each conviction.

Proceedings and Sentencing

• On April 8, 1957, at approximately 10:00 p.m., the appellant was arraigned.
• Upon entering a plea of guilty, she was sentenced to 6 months and 1 day of prision correccional, in addition to an extra penalty of 10 years and 1 day of prision mayor for being a habitual delinquent.
• The appellant subsequently began serving the sentence, prompting her to file a petition for habeas corpus on February 9, 1960.

Petition Grounds and Alleged Violations

• The appellant asserted that her constitutional right to due process was violated on two main grounds:
• She was not given sufficient time (less than 48 hours) to prepare her defense upon arrest and arraignment.
• She was not represented by counsel, claiming that she was not informed of her right to secure legal assistance.
• The petitioner relied on section 7 of Rule 114, arguing that a defendant in a criminal case is entitled to at least two days to prepare for trial, which she contended was not observed in her case.

Issue:

Whether the appellant’s constitutional right to due process was violated due to the allegedly insufficient time provided to prepare her defense.

• Specifically, whether the less than 48-hour period between the time of arrest and the arraignment constituted a breach of the procedural due process rights.

Whether the appellant was denied her right to be represented by counsel during the proceedings.

• The issue also encompasses whether the failure to secure legal representation, or a waiver thereof, invalidated the due process requirements.

• The applicability of Rule 114 regarding the minimum time for defense preparation in cases where the defendant pleads guilty.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)