Facts:

In the case of Conrado Martin vs. Gen. Vicente M. Eduardo, the petitioner, Conrado Martin, filed a petition for habeas corpus seeking his release from confinement. 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, which were described as "three-folded." Throughout his incarceration, Martin escaped from prison multiple times: first on October 14, 1963, and was recommitted on November 28, 1963; again on May 1, 1965, and recommitted on June 22, 1968; a third escape occurred on October 3, 1969, with recommitment on October 10, 1969; and finally, he escaped for the fourth time on July 28, 1979, but was recommitted on August 8, 1979. On June 12, 1976, the President of the Philippines commuted Martin's original sentence to thirty years. Despite this clemenc...

Facts:

1. Initial Incarceration: Conrado Martin was first received at the New Bilibid Prison (NBP) on April 22, 1959, to serve a 40-year sentence for various crimes. His sentences were "three-folded."
2. Escapes and Recommitments:
   • First Escape: Escaped on October 14, 1963, and was recommitted on November 28, 1963.
   • Second Escape: Escaped on May 1, 1965, and was recommitted on June 22, 1968.
   • Third Escape: Escaped on October 3, 1969, and was recommitted on October 10, 1969.
   • Fourth Escape: Escaped on July 28, 1979, and was recommitted on August 8, 1979.
3. Commutation of Sentence: On June 12, 1976, the President of the Philippines commuted Martin's original 40-year sentence to 30 years.
4. Additional Sentence for Evasion: After his fourth escape, Martin was charged with evasion of service of sentence, adding 2 years, 4 months, and 1 day to his commuted 30-year sentence.
5. Total Time at Large: During his four escapes, Martin was at large for a total of 3 years, 3 months, and 11 days.
6. Expiration of Sentence: The commuted sentence plus the additional sentence for evasion expired on April 29, 1982. However, the Acting Director of Prisons refused to release Martin, arguing that the time he spent at large should not be counted as service of his sentence.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Deprivation of Liberty: A sentence of imprisonment involves the deprivation of liberty. Since Martin was not deprived of his liberty during the periods he was at large, those periods cannot be counted as service of his sentence.
2. Legal Requirement for Service of Sentence: Article 89 of the Revised Penal Code mandates that penalties involving deprivation of liberty must be served in penal institutions. Martin’s time at large does not meet this requirement.
3. No Entitlement to Release: The Court held that Martin is not entitled to be released until he has fully served his sentence, including the additional time imposed for evasion of service, within a penal institution.