G.R. No. 139033 - Del Castillo vs. Torrecampo

On May 17, 1982 (Barangay Election Day), at around 8:15 P.M. in Barangay Ombao, Municipality of Bula, Camarines Sur, petitioner Jovendo del Castillo allegedly struck an electric bulb and two kerosene lamps during the vote count at Voting Center No. 24, plunging the room into darkness and disrupting the Board of Election Tellers.
On March 8, 1983, Criminal Case No. F-1447 was filed in RTC Branch 33, Camarines Sur, charging petitioner with disorderly conduct under Section 178(nn) of PD 1296 (1978 Election Code).

Petitioner pleaded not guilty; trial ensued. On January 14, 1985, the trial court found him guilty beyond reasonable doubt and imposed an indeterminate penalty of 1 year (minimum) to 3 years (maximum) imprisonment.
Petitioner appealed to the Court of Appeals, which on June 14, 1986 rendered a final decision affirming the conviction. Execution of sentence was set for October 14, 1987.

On October 12, 1987, petitioner moved to reset execution of judgment; the motion was denied. At the scheduled execution, petitioner failed to appear, prompting issuance of an arrest warrant and forfeiture of his bail bond. He remained at large.
On October 24, 1997, ten years later, petitioner filed a motion to quash the warrant on the ground that the penalty had prescribed. The trial court denied both the motion and his subsequent motion for reconsideration.

Petitioner filed a Petition for Certiorari in the Court of Appeals, challenging the orders denying his motion to quash.
On November 20, 1998, the Court of Appeals dismissed the petition for lack of merit. A motion for reconsideration was denied on June 14, 1999.
Petitioner then elevated the case to the Supreme Court via petition for review on certiorari.

Whether the penalty imposed upon petitioner has prescribed under Article 93 of the Revised Penal Code.
How to interpret Article 93 in relation to Article 157 of the Revised Penal Code, particularly the requirement of “escape during the term of the sentence.”