Case Digest (G.R. No. 166401)
Facts:
In the case of Conrado Martin vs. General Vicente M. Eduardo, G.R. No. 62627, dated March 18, 1983, Conrado Martin, the petitioner, filed a petition for habeas corpus seeking release from his confinement in the New Bilibid Prison (NBP) in Muntinlupa, Metro Manila, where he was held as prisoner No. 51512-P. Martin was originally sentenced to serve a definitive sentence of 40 years for various crimes on April 22, 1959. His sentence was later commuted to 30 years by the President of the Philippines on June 12, 1976. Throughout his imprisonment, Martin escaped four times. His first escape occurred on October 14, 1963, followed by a recommitment on November 28, 1963. He escaped a second time on May 1, 1965, and was recommitted on June 22, 1968. A third escape transpired on October 3, 1969, with recommitment shortly thereafter on October 10, 1969. Following his fourth escape on July 28, 1979, he was recommitted on August 8, 1979. After his final escape, the aut
Case Digest (G.R. No. 166401)
Facts:
- Background of the Inmate and Sentencing
- Conrado Martin was incarcerated at the New Bilibid Prison (NBP) in Muntinlupa, Metro Manila, as Prisoner No. 51512-P.
- He was first received at the NBP on April 22, 1959, to serve a definite sentence of 40 years for various crimes.
- The sentence was imposed in a "three-folded" manner, implying multiple counts or concurrent aspects in his punishment.
- Details of Escapes and Recommitments
- First Escape and Recommitment
- Escaped on October 14, 1963.
- Recommitted on November 28, 1963.
- Second Escape and Recommitment
- Escaped on May 1, 1965.
- Recommitted on June 22, 1968.
- Third Escape and Recommitment
- Escaped on October 3, 1969.
- Recommitted a few days later on October 10, 1969.
- Fourth Escape and Recommitment
- Escaped on July 28, 1979.
- Recommitted on August 8, 1979, due to diminished ability to evade capture over time.
- Sentence Modifications and Additional Charges
- The petitioner's original 40-year sentence was commuted to 30 years on June 12, 1976 by the President of the Philippines.
- Following his fourth escape, he was charged with evasion of service of sentence, which added an additional sentence of two (2) years, four (4) months, and one (1) day.
- Computation of Time Served and Controversial Period
- The total duration during his escapes amounted to three (3) years, three (3) months, and eleven (11) days.
- If the time at large was counted as service of sentence, the commuted sentence plus the additional charge would have expired on April 29, 1982.
- The Acting Director of Prisons, however, did not include the period the petitioner was at large in computing his service of the sentence.
- Legal Provision Involved
- Article 89 of the Revised Penal Code requires that penalties, which entail deprivation of liberty, must be served in designated penal establishments as provided by law.
- The provision underscores that time spent outside prison walls (while at large) cannot be equated with service of sentence.
Issues:
- Central Question
- Whether the period during which Conrado Martin was at large during his four escapes should be included as part of the service of his sentence.
- Sub-Issues
- Whether the time spent outside the penal institution equates to the deprivation of liberty the law contemplates under the sentence.
- How Article 89 of the Revised Penal Code impacts the computation of time served when periods of escape are involved.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)