Facts:
Ricardo Parulan, the petitioner, was serving a sentence of life imprisonment commuted by the President to twenty years and was confined in the state penitentiary at Muntinglupa, Rizal before being transferred in October, 1964 to the military barracks at Fort Bonifacio, Makati, Rizal, under the custody of the Stockade Officer; in that month he escaped from confinement, was later recaptured in the City of Manila, and was prosecuted before the
Court of First Instance of Manila for the crime of
evasion of service of sentence, penalized under
Article 157 of the Revised Penal Code, after due trial was found guilty and sentenced on August 3, 1966, whereupon he filed a petition for a writ of
habeas corpus in the Supreme Court, directed to the
Director of Prisons, alleging that the conviction and sentence were illegal because the trial court lacked jurisdiction over his person and the offense; the petition asserted that his confinement under the respondent was therefore unlawful and sought immediate release.
Issues:
Was the
Court of First Instance of Manila vested with jurisdiction to try, convict, and sentence
Ricardo Parulan for the crime of
evasion of service of sentence?; If the offense of evasion of service of sentence is a continuing crime, may the offender be validly arrested and tried at any place where he is found after escape?
Ruling:
Ratio:
Doctrine: