Title
Narciso Alvarez y Cortes vs. The Director of Prisons
Case
G.R. No. 1809
Decision Date
Mar 19, 1948
The Supreme Court ruled that a pardon for murder does not nullify the penalty for evasion of service of sentence, as they are distinct offenses.
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Case Digest (G.R. No. 1809)

Facts:

  • The case is Narciso Alvarez y Cortes vs. The Director of Prisons, G.R. No. 1809, decided on March 19, 1948.
  • Narciso Alvarez was convicted of murder and sentenced to imprisonment.
  • He received a conditional pardon from the Chief Executive, which remitted his murder penalty.
  • Before the pardon, Alvarez committed evasion of service of his sentence and was convicted for it.
  • The lower court denied his habeas corpus petition, stating the pardon did not apply to the evasion conviction.
  • Alvarez argued that the evasion offense was dependent on the original murder sentence, citing People v. Jose.
  • The court maintained that evasion of service of sentence is a distinct crime under Article 157 of the Revised Penal Code.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the motion for reconsideration.
  • The court affirmed that the conditional pardon for murder did not extend to the penalty for evasion of service of sentence.
  • ...(Unlock)

Ratio:

  • The court distinguished between the nature of the offenses involved.
  • Evasion of service of sentence, under Article 157 of the Revised Penal Code, is a public offense that undermines legal authority.
  • The crime is independent of the original offense for which the pardon was granted.
  • A conditional pardon is likened to a contract, requiring compliance with specific conditions.
  • Violating these conditions, ...continue reading

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