Case Digest (G.R. No. 141718)
Facts:
- Petitioner: Benjamin Pangan y Rivera
- Charge: Simple seduction in Criminal Case No. 85-816
- Court: Municipal Trial Court of Angeles City, Branch 3
- Defense Counsel: Atty. Eduardo Pineda
- Trial Issue: Pangan's absence at hearings led to no evidence being presented by the defense
- Conviction Date: September 16, 1987
- Sentence: Two months and one day of arresto mayor
- RTC Affirmation: October 24, 1988
- Promulgation Date: August 9, 1991
- Absence: Pangan and his counsel did not appear
- Arrest Order: Issued due to non-appearance
- Apprehension: January 20, 2000, detained at Mabalacat Detention Cell
- Petition: Filed for a Writ of Habeas Corpus, claiming illegal arrest and prescription of penalties
- RTC Decision: Petition denied, leading to the present appeal
Issue:
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Ruling:
- The prescriptive period of penalties begins to run only when the convict evades the service of the sentence by escaping during the term of his sentence.
- The Supreme Court affirmed the RTC's decision, ruling that Pangan...(Unlock)
Ratio:
- Article 93 of the Revised Penal Code: Prescription of penalties commences from the date when the convict evades the service of the sentence.
- Supporting Cases: "Infante v. Warden," "Tanega v. Masakayan," and "Del Castillo v. Torrecampo"
- Key Point: Prescription applies only to those convicted by final judgment and serving a sentence involving deprivation of liberty.
- Pangan's Situation: Never served any part of his sentence before arrest, so the prescription period never began.
- Outcome: Pangan had...continue reading
Case Digest (G.R. No. 141718)
Facts:
The case of "Pangan v. Gatbalite" involves petitioner Benjamin Pangan y Rivera, who was indicted for simple seduction in Criminal Case No. 85-816 at the Municipal Trial Court of Angeles City, Branch 3. During the trial, Pangan's counsel, Atty. Eduardo Pineda, submitted the case for decision without presenting any evidence due to Pangan's constant absence at hearings. On September 16, 1987, Pangan was convicted and sentenced to two months and one day of arresto mayor. The Regional Trial Court (RTC) affirmed the decision on October 24, 1988. On August 9, 1991, the case was called for promulgation of the decision, but Pangan and his counsel did not appear. Consequently, the court issued an order of arrest against Pangan. He was apprehended on January 20, 2000, and detained at the Mabalacat Detention Cell. Pangan filed a Petition for a Writ of Habeas Corpus, claiming his arrest was illegal and his criminal liability had been extinguished due to the prescription of penalties. The RTC denied the petition, leading to the present appeal....