A.C. No. 5161 - Re: Rolando S. Torres

The case involves petitioner Juanito Llobrera Y Baylon who filed a petition for habeas corpus.
He was charged in the Municipal Court of Dagupan for violating article 155, paragraph 4, of the Revised Penal Code (RPC), which punishes any person "who, while intoxicated or otherwise, shall cause any disturbance or scandal in public places."
By pleading guilty, petitioner was sentenced to one month’s imprisonment for the specific offense.

In addition to the one month’s imprisonment, the petitioner received an additional penalty of 2 years, 4 months, and 1 day of prision correccional.
This additional penalty was imposed under the habitual delinquency law due to his two previous convictions for the same offense.
The habitual delinquency law cited refers to article 62 of the Revised Penal Code, as amended by Republic Act No. 18.

The petitioner had already served the one month’s imprisonment for the specific crime charged.
However, he was still confined at the New Bilibid Prisons in Muntinglupa to complete the additional penalty as a habitual delinquent.
Petitioner contended that the additional penalty was null and void because the habitual delinquency law applies only to crimes such as serious or less serious physical injuries, robbery, theft, estafa, or falsification, not to the crime described in article 155 of the Revised Penal Code.

He argued that the habitual delinquency law should not apply to the crime of causing disturbance or scandal under article 155 of the RPC.
As a result, the additional penalty of 2 years, 4 months, and 1 day of prision correccional was erroneously and unlawfully imposed.

The Solicitor General recommended approval of the petition.
He raised the contention that the additional penalty was not only inapplicable under the habitual delinquency law but also represented a punishment in excess of the power of the Municipal Court to impose.
References were made to the authorities: Cruz vs. Director of Prisons and People vs. Costosa, emphasizing that the additional penalty for habitual delinquency must be considered in determining the jurisdiction of the court.

Whether the imposition of an additional penalty of 2 years, 4 months, and 1 day of prision correccional for habitual delinquency was legally proper given the nature of the crime charged under article 155 of the RPC.
Whether the habitual delinquency law can be extended to cover crimes other than those expressly enumerated (i.e., serious or less serious physical injuries, robbery, theft, estafa, or falsification).

Whether the Municipal Court of Dagupan exceeded its jurisdiction by imposing an additional penalty beyond its authorized power under the law.
Whether the additional penalty served as a punishment in excess of the court’s jurisdiction, thus rendering it void.

Whether the habitual delinquency law, as amended, should apply to the offense of causing disturbance or scandal in public places.
Whether the law’s strict limitations to specific crimes invalidate the application for the crime in question.