Title
Aspra y Crusillo vs. Director of Prisons
Case
G.R. No. L-3643
Decision Date
Mar 7, 1950
Petitioner, imprisoned for multiple estafa cases, sought habeas corpus, claiming excessive imprisonment under the threefold rule. Supreme Court ruled his detention exceeded legal limits, ordering immediate release.
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Case Digest (G.R. No. L-3643)

Facts:

  1. Petitioner and Respondent: Carlos Aspra y Crusillo (petitioner) filed a petition for a writ of habeas corpus against the Director of Prisons (respondent).
  2. Imprisonment Details: The petitioner was committed to the New Bilibid Prison on October 23, 1948, to serve six sentences for estafa.
  3. Sentences Imposed: In each of the six cases, the Municipal Court of Manila imposed a penalty of 3 months and 11 days of arresto mayor, along with indemnity totaling P144.
  4. Duration of Imprisonment: By the time of the petition, the petitioner had already served 1 year, 3 months, and a number of days in prison.
  5. Legal Precedents: The case references U.S. vs. Ballesteros (1 Phil. 208) and Bagtas vs. Director of Prisons (85 Phil. 24), which established the threefold rule under Article 70 of the Revised Penal Code.

Issue:

  • (Unlock)

Ruling:

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Ratio:

  1. Threefold Rule Application: Under Article 70 of the Revised Penal Code, the total penalty for multiple offenses cannot exceed three times the most severe penalty imposed for a single offense.
  2. Precedent: The Court relied on U.S. vs. Ballesteros and Bagtas vs. Director of Prisons, which established that the total imprisonment for multiple estafa cases should not exceed three times the penalty for one offense, plus subsidiary imprisonment for indemnity.
  3. Excess Imprisonment: The petitioner had already served 1 year, 3 months, and a number of days, which exceeded the maximum period allowed under the threefold rule.
  4. Entitlement to Release: The petitioner was entitled to immediate release as his continued imprisonment violated the threefold rule.


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