Title
Camat vs. Director of Prisons
Case
G.R. No. L-2092
Decision Date
Apr 6, 1948
Justo Camat, convicted for illegal firearm possession during Japanese occupation, was conditionally pardoned but later re-arrested. The Supreme Court nullified his conviction, ruling it political, and ordered his restoration as a detention prisoner, citing *Peralta vs. Director of Prisons*.
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Case Digest (G.R. No. L-2092)

Facts:

  1. Initial Conviction and Imprisonment:
    Petitioner Justo Camat was committed to the New Bilibid Prisons on June 30, 1944, to serve a six-year sentence for illegal possession of firearms, imposed by the Court of Special and Exclusive Criminal Jurisdiction. He was also fined P1,000, with a subsidiary imprisonment of one year in case of non-payment. Camat alleged that he was sentenced as a guerrilla.

  2. Release Under Conditional Pardon:
    On February 5, 1945, Camat was released from confinement under a mass conditional pardon issued by the Japanese detachment commander for the New Bilibid Prisons.

  3. Re-arrest and Detention:
    On February 20, 1947, Camat was arrested and charged with robbery. He was committed as a detention prisoner to the New Bilibid Prisons on February 25, 1947.

  4. Change in Prisoner Status:
    On February 25, 1948, the Director of Prisons changed Camat's status from a detention prisoner to a convict, based on the theory that the pardon granted to him on February 5, 1945, was null and void.

  5. Petitioner’s Complaints:
    Camat argued that the Director of Prisons acted illegally by transferring his status, resulting in the loss of privileges such as weekly visits, confinement in cells for convicted criminals, and being forced to wear prisoner’s garb and perform labor. He claimed that the transfer was made in bad faith, as the Director ignored the Supreme Court’s decision in Peralta vs. Director of Prisons, which declared that crimes of illegal possession of firearms during the occupation were political and that the judgments of the Court of Special and Exclusive Criminal Jurisdiction ceased to be valid upon liberation.

  6. Prayers of the Petitioner:
    Camat sought restoration to his status as a detention prisoner, a declaration that his conviction for illegal possession of firearms was null and void, and prosecution of the Director of Prisons for the illegal transfer.

  7. Solicitor General’s Recommendation:
    The Solicitor General, representing the Director of Prisons, recommended that Camat be restored to his former status as a detention prisoner, in line with the Peralta case.

Issue:

  1. Whether the pardon granted to Camat on February 5, 1945, was valid.
  2. Whether the Director of Prisons acted lawfully in transferring Camat’s status from a detention prisoner to a convict.
  3. Whether Camat’s conviction for illegal possession of firearms during the occupation remained valid after the liberation of the Philippines.
  4. Whether Camat is entitled to restoration of his status as a detention prisoner and other reliefs sought.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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