Case Digest (G.R. No. 8252)
Facts:
Adriano Trono Felipe et al. v. The Director of Prisons, G.R. No. 8252, January 18, 1913, the Supreme Court, Carson, J., writing for the Court; Arellano, C.J., Torres and Mapa, JJ., concur; Trent, J., dissents.Petitioners Adriano Trono Felipe and Aniceto Trono Felipe were convicted by the Court of First Instance of the Province of Bulacan and, by commitment dated March 10, 1911, were sentenced to suffer two years, eleven months, and ten days of prision correccional. That conviction was affirmed on appeal to this Court (reported at 21 Phil. Rep. 640). They were thereafter detained at Bilibid by the respondent, the Director of Prisons, pursuant to the commitment.
The petitioners filed an application for a writ of habeas corpus seeking discharge on the ground that their conviction for "abduction of a virgin with her consent" (rapto de una doncella con su anuencia) was erroneous because, they alleged, the woman involved was actually over eighteen years of age at the time of the alleged offense. Counsel relied principally on the Court’s later decision in United States v. Fideldia (22 Phil. Rep. 372, decided March 26, 1912), which construed the penal provisions on rapto as applying to females under 18 years of age (reducing a prior age reference from 23 to 18), and argued that, under that doctrine, the petitioners’ detention was illegal.
The Court (Carson, J.) reviewed the factual posture and procedural history: the trial court had jurisdiction of the person and of the offense throughout; the point as to the victim’s age had not been pressed at trial or on the earlier appeal; and if the petitioners’ present allegations were true the conviction would have been erroneous under the Fideldia doctrine. The Court nevertheless denied the habeas corpus petition, holding that habeas corpus is not the proper remedy to correct errors of fact or law in a final criminal judgment where the trial court had jurisdiction, and that a commitment based on a final judgment is conclusive evidence of th...(Subscriber-Only)
Issues:
- Is habeas corpus an available remedy to test the legality of detention where petitioners contend their conviction for rapto was erroneous under the later decision in United States v. Fideldia, but the trial court had jurisdiction and the conviction is final?
- If the woman allegedly abducted was in fact over eighteen years of age, did that fact render the petitioners’ conviction for rapto de una doncella con su anuencia legally ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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