Facts:

The case revolves around Melencio Andres filing a petition for habeas corpus on behalf of his son, Leonardo Andres y Santos, who was incarcerated in Bilibid Prison in Muntinglupa. Leonardo had been sentenced in four different criminal cases related to illegal possession of firearms and crimes against property. Specifically, he faced the following convictions: (1) Criminal Case No. 158 in the Court of First Instance of Manila, sentenced to four months and a day to a maximum of one year, plus other determinations; (2) Criminal Case No. 73743, also in Manila, where he received a sentence of three months and a P200 fine; (3) Criminal Case No. 640, sentenced to four months of arresto mayor and P5,030 as compensation as an accomplice in a robbery; and (4) Criminal Case No. 3215, with a penalty of six months and a day of prison correctional for robbery with less serious injuries, in addition to six years and a day for habitual delinquency with a required indemnification of P745 to the

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Facts:

Background of the Case

• Melencio Andres filed a petition for habeas corpus on behalf of his son, Leonardo Andres y Santos (alias Fernando Santiago y Garcia), who is incarcerated at the Bilibid Prison in Muntinlupa.
• The petition challenges the imposition of multiple penal sentences stemming from four separate criminal causes.

Details of the Criminal Causes

• Causa Criminal No. 158
• Prosecuted in the Juzgado de Primera Instancia of Manila.
• Conviction for illegal possession of firearms resulting in a sentence ranging from 4 months and 1 day to 8 months and 21 days.
• Causa Criminal No. 73743
• Also heard in the Juzgado de Primera Instancia of Manila.
• Resulted in a sentence of 3 months imprisonment and a fine of P200 for illegal possession of firearms.
• Causa Criminal No. 640
• Handled by the Juzgado de Primera Instancia of Manila.
• Involved a conviction as an accomplice in a robbery.
• Imposed penalties included 4 months of arrest mayor and an indemnification of P5,030.
• Causa Criminal No. 3215
• Also adjudicated by the Juzgado de Primera Instancia of Manila.
• Resulted in a dual sentence:
• Six months and 1 day of prision correctional for robbery with less serious injuries.

ii. An additional penalty of six years and 1 day for being declared a habitual delinquent, along with an indemnification of P745.

Chronology and Procedural Background

• Leonardo Andres began serving his sentence on December 15, 1943.
• He was placed on provisional release during the Japanese regime on May 4, 1944.
• He was re-incarcerated on September 11, 1946, and was still in custody at the time of the petition.
• The prison record detailing the orders of imprisonment is derived not from the original querella (the formal charge) but from a prison order signed by a judge, as the original court files were destroyed during the liberation of Manila in February 1945.

Disputed Evidence and Allegations

• The petitioner contends that a paragraph in the querella of the fourth cause is defective because it merely states, "That the accused is a habitual delinquent, he having been previously convicted three times of a crime against property," without specifying crucial details such as the dates of previous offenses, prior convictions, or release dates.
• The petitioner argues that this omission renders the imposition of the additional penalty for habitual delinquency null and void.
• It is alleged that the paragraph in question is not a transcription of the original charge but a reproduction of the language found in paragraph 3 of a previous decision (Pueblo contra Masonson and Katibak), which set the doctrinal requirements for establishing habitual delinquency.

Administrative and Evidentiary Considerations

• The only extant prison record is an order of incarceration dated December 16, 1943, issued by Roberto Concepcion, which outlines the sentence including both the prision correctional term and the additional penalty for habitual delinquency.
• The presumption is that the judge who issued this order complied with Article 62 of the Revised Penal Code and the established doctrine from Pueblo contra Masonson regarding the specification of prior convictions.
• The petition further details the computation of Leonardo Andres’ prison term:
• With deductions for abono por buena conducta and a period during which he was out of prison due to an escape, the minimum and maximum dates for release are calculated to be May 26, 1950, and June 11, 1951, respectively.
• Without accounting for the escape and only factoring in the abono, the release date is projected as October 14, 1953.
• Should the abono for the escape not be granted, the release date would be September 30, 1955.

Issue:

Sufficiency of the Querella

• Whether the failure of the querella to specify the dates of previous convictions, the dates of sentencing, and the dates of release renders the additional penalty for habitual delinquency defective and null.

Validity of the Transcription

• Whether the paragraph cited by the petitioner in the querella, which allegedly merely copies language from a prior decision (Pueblo contra Masonson), can be used as a basis for imposing an additional penalty for habitual delinquency.

Judicial Compliance with Procedural and Substantive Requirements

• Whether, notwithstanding the alleged defects, the judge’s order—based on the official prison record—is consistent with the requirements of Article 62 of the Revised Penal Code and established jurisprudence, thereby justifying the additional penalty.

Impact on the Prisoner’s Release

• Whether the omission in the querella effectively entitles Leonardo Andres to immediate release by excluding the additional sentence for habitual delinquency as improperly imposed.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)