Case Digest (G.R. No. L-1540)
Facts:
Simplicio Mag. Guinto, in behalf of prisoner, his cousin, Leonardo Andres, Petitioner, vs. The Director of Prison, Respondent, G.R. No. L-1540, January 26, 1948, Supreme Court En Banc, Paras, J., writing for the Court.Petitioner filed a habeas corpus to secure the immediate release of his cousin, Leonardo Andres, detained at Bilibid Prisons, Muntinlupa, Rizal. The petition challenged Andres's confinement as being founded on a judgment of conviction rendered by the Court of First Instance of Manila on December 15, 1943, which petitioner argued was null and void because it was rendered by a court established under the Japanese occupation and imposed a penalty inconsistent with then-applicable laws.
The Director of Prisons answered that the December 15, 1943 judgment convicted Andres of robbery under the Revised Penal Code and therefore was not political in character; moreover, Andres had subsequent convictions in September and November 1946 by the Court of First Instance of Manila. The prison record (Annex 2) showed an indeterminate minimum term (with good-conduct allowance) that would not expire until October 25, 1949.
The Supreme Court, sitting En Banc, denied the petition. The Court held that the 1943 judgment, which convicted Andres of robbery as defined under the Revised Penal Code, was not political in nature and remained valid after the termination of the Japanese military occupation; the Court relied on precedents including Herrero and Crisostomo v. Diaz, Alcantara v. Director of Prisons, and Co Lim Cham v. Valdez Tan Keh. The Court also noted Andres’s later valid convictions after liberation and concluded that release was not in order. The petition was denied without costs.
A separate opinion by Justice Hilado concurred in the denial of the petition on the ground that the 1946 judgments lawfully detained Andres but dissented insofar as the majority upheld the validity of the December 15, 1943 judgment. Justice Perfecto dissent...(Pro-only)
Issues:
- Was the judgment of conviction dated December 15, 1943, rendered during the Japanese occupation, valid and a lawful basis for Leonardo Andres's continued confinement?
- If the 1943 judgment were invalid, do Andres's subsequent convictions and his prison record sustain his lawful detention and preclud...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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