Case Digest (G.R. No. L-810)
Case Digest (G.R. No. L-810)
Facts:
Manuel Artigas Losada v. Juan Acenas (consolidated with Getulio Geocada v. Juan Acenas, Santiago Aguda v. Juan Acenas, Francisco Danao v. Juan Acenas), G.R. Nos. L-810, L-811, L-812, L-813, March 31, 1947, the Supreme Court En Banc, Bengzon, J., writing for the Court.The four petitioners — Manuel Artigas Losada, Getulio Geocada, Santiago Aguda, and Francisco Danao — were inmates of the Davao Penal Colony at Inagawan, Palawan, serving various sentences for estafa, illegal possession of counterfeit money, homicide, and abduction with rape, respectively, with projected release dates (with good conduct allowance) ranging from April 25, 1947 to June 19, 1948. In July 1946 the justice of the peace of Puerto Princesa, acting in the absence of the judge of first instance under Act No. 2131, issued an order directing their immediate release by writ of habeas corpus.
The justice of the peace based his order on his interpretation that petitioners were entitled to a one-fifth special time allowance under Article 98 and Article 158 of the Revised Penal Code because they had remained loyal and did not escape during the disorder caused by the war; he reasoned that their conduct merited the same or greater reward than convicts who escaped during a calamity and later surrendered within the statutory period. The respondent, Juan Acenas, Superintendent of the Davao Penal Colony, appealed that order to the Supreme Court.
The Supreme Court, on appeal, reviewed the justice of the peace’s construction of Articles 98 and 158 and considered whether the statutory deduction applies to convicts who did not evade the service of their sentences by leaving confinement during the wartime disorder. No TROs, amici, or oral-argument particulars are reported in the opinion.
Issues:
- Did the justice of the peace properly order the release of the petitioners by habeas corpus under Articles 98 and 158 of the Revised Penal Code?
- Do Articles 98 and 158 of the Revised Penal Code entitle convicts who remained in custody during wartime disorder (and did not escape) to the one-fifth deduction or other special allowance contemplated therein?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)