Facts:

The case involves Flora Cadimas as the petitioner and the Director of Prisons as the respondent. The events leading to this case began with the conviction of Donato Cachola, the husband of the petitioner, who was imprisoned at the Iwahig Penal Colony. On January 18, 1955, the Court of First Instance of Ilocos Sur sentenced him to five years of imprisonment and a fine of P1,000 for the crime of illegal possession of military ammunition, specifically a hand grenade, which was allegedly committed on or about March 16, 1951. This conviction was based on the assertion that Cachola violated Republic Act No. 4. However, it is crucial to note that during March 1951, the possession of unlicensed firearms or ammunition was not considered unlawful due to the provisions of Republic Act No. 482, which extended the deadline for surrendering unlicensed arms and ammunition to June 10, 1951. During this extended period, only the act of using or carrying such items was punishable, and neither ...

Facts:

1. Petitioner and Respondent:

   • Petitioner: Flora Cadimas
   • Respondent: The Director of Prisons

2. Imprisonment of Donato Cachola:

   • Donato Cachola, the husband of the petitioner, was imprisoned at the Iwahig Penal Colony under the control of the respondent.
   • He was sentenced to five (5) years imprisonment and a fine of P1,000, with subsidiary imprisonment in case of insolvency, by the Court of First Instance of Ilocos Sur on January 18, 1955.
   • The conviction was for the crime of illegal possession of military ammunition (hand grenade), allegedly committed on or about March 16, 1951, in violation of Republic Act No. 4.

3. Legal Context:

   • In March 1951, unlicensed possession of firearms or ammunition was not unlawful because Republic Act No. 482 extended the period for the surrender of unlicensed arms and ammunition to June 10, 1951.
   • During this extended period, only the use or carrying of such items on one’s person was punishable.
   • Neither of these acts (use or carrying) was attributed to Donato Cachola.

4. Plea of Guilty:

   • Donato Cachola pleaded guilty to the information, but this plea only admitted the facts alleged in the information, not that the acts charged were unlawful.
   • The plea did not cure the defect in the court’s jurisdiction.

5. Defective Information:

   • The information filed against Donato Cachola did not charge any crime, rendering his conviction void.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdictional Defect: A court cannot convict a person for an act that was not a crime at the time it was committed. The information must allege facts that constitute a crime under the law.
2. Plea of Guilty: A plea of guilty only admits the facts alleged in the information, not the legal conclusion that those facts constitute a crime. It does not cure a jurisdictional defect.
3. Habeas Corpus: The writ of habeas corpus is a remedy to secure the release of a person unlawfully detained, especially when the conviction is void due to lack of jurisdiction or failure to charge a crime.