Facts:

The case at hand pertains to Pete C. Lagran, the petitioner, who was convicted by the Regional Trial Court of Quezon City on April 18, 1994, for three counts of violating Batas Pambansa Blg. 22. The court sentenced him to one year of imprisonment for each count, along with a fine of P125,000.00 and a provision for subsidiary imprisonment in case of insolvency. Following his conviction, Lagran appealed the decision, but the Court of Appeals dismissed the appeal on July 11, 1997, due to his failure to file the required appellant's brief. Consequently, the appellate court's decision became final and executory on August 6, 1997, with the entry of judgment completed on March 5, 1998. Subsequently, Lagran was committed to the Quezon City Jail on February 24, 1999, by a Commitment Order issued by Hon. Elsa I. De Guzman, the presiding judge of the Regional Trial Court. Later, on April 3, 1999, he was transferred to the New Bilibid Prison, where he continued to serve his sentence

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Facts:

Conviction and Sentencing

• On April 18, 1994, petitioner Pete C. Lagran was convicted by the Regional Trial Court of Quezon City for three counts of violation of Batas Pambansa (BP) Blg. 22.
• He was sentenced to suffer imprisonment of one year for each count and to pay a fine of P125,000.00, with subsidiary imprisonment in case of insolvency.

Appellate Proceedings and Finality of Judgment

• Petitioner appealed the trial court’s decision to the Court of Appeals; however, the appeal was dismissed on July 11, 1997 due to the failure to file the appellant’s brief.
• The appellate decision became final and executory on August 6, 1997, with the entry of judgment on March 5, 1998.

Commitment and Incarceration

• By virtue of a Commitment Order issued by Hon. Elsa I. De Guzman (Presiding Judge, RTC Quezon City, Branch 93), petitioner was committed to the Quezon City Jail on February 24, 1999.
• On April 3, 1999, he was transferred to the New Bilibid Prison, where he has been serving his sentence continuously.

Habeas Corpus Petition and Allegations

• On March 19, 2001, petitioner filed the instant petition for habeas corpus, claiming that he had allegedly completed the service of his sentence.
• He argued that under Article 70 of the Revised Penal Code, if penalties or sentences imposed are identical and emanate from one court and one complaint, they should be served simultaneously.
• Petitioner asserted that because he had been incarcerated for two years and four days (from February 28, 2001), his detention in the New Bilibid Prison now lacked a legal basis.

Legal Discussion on the Nature of Penalties

• The decision discusses Article 70 of the Revised Penal Code, which allows the simultaneous service of penalties only if their nature permits.
• It enumerates penalties that can be concurrently served, such as various forms of disqualification, suspension, destierro, public censure, and fines or bonds, but distinguishes these from penalties involving deprivation of liberty.
• The court clarifies that penalties consisting in imprisonment, being a deprivation of liberty, must be served successively rather than concurrently.

Issue:

• Whether petitioner’s continued detention is legally justified, given his claim of having completed his sentence.
• Whether the provisions of Article 70 of the Revised Penal Code, which allow for concurrent service, can be applied to penalties that involve imprisonment.
• Whether the nature of the penalty imposed—imprisonment—necessitates that multiple prison terms be served successively.
• Whether the petition for habeas corpus should be granted on the basis that the petitioner has supposedly fulfilled the required period of incarceration.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)